United States securities and exchange commission logo
June 6, 2022
Rongguo Wei
Chief Financial Officer
Alset EHome International Inc.
4800 Montgomery Lane, Suite 210
Bethesda, MD 20814
Re: Alset EHome
International Inc.
Form 10-K for the
year ended December 21, 2021
Filed March 31,
2022
File No. 001-39732
Dear Mr. Wei:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the year ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Real Estate Assets, page 43
1. We note your disclosure
related to the breakdown of your capitalized construction costs
which includes an
impairment reserve of approximately $5.2 million for the years ended
December 31, 2021 and
December 31, 2020. Please tell us the nature of the impairment
reserve and the reason
for establishing such a reserve. In that regard, please tell us how the
establishment of such
an impairment reserve is consistent with the guidance on
impairments for long
lived assets in ASC 360-10-35. Specifically, it is noted that such
guidance outlines a two
step approach based on a trigger test to the extent there are any
impairment indicators
and to the extent an impairment is identified after applying the two
step approach, any
impairment recognized would adjust the carrying amount of the long
lived asset with
restoration of a previously recognized impairment loss being prohibited.
See ASC 360-10-35-17
and ASC 360-10-35-20.
Rongguo Wei
Alset EHome International Inc.
June 6, 2022
Page 2
Note 2. Summary of Significant Accounting Policies
Revenue Recognition and Cost of Sales, page 76
2. We note your disclosure on page 5 that as part of the contract with
NVR, upon
establishment of FFB assessments on the lots, the Company is obligated
to credit NVR
with an amount equal to one year of FFB assessment per each lot
purchased by
NVR. Please expand your policy to disclose how you account for such
credits. Your
disclosure should outline whether the Company recognizes such credits
as a reduction of
revenue or costs of sales. In that regard, please tell us your
consideration of the guidance
in ASC 606-10-32-25 through 27.
Note 10. Equity, page 95
3. We note your disclosure on page 99 that on July 13, 2020, due to share
grants and warrant
exercises, the Company s ownership percentage of Alset International
fell below 50%, the
entity was deconsolidated in accordance with ASC 810-10-40-5 and a
gain of
approximately $53 million was recorded. We further note on page 68
that as of December
31, 2021 you own 76.8% of Alset International and it is once again a
consolidated
subsidiary of the Company. In order to better understand the Company's
accounting
related to the Alset International subsidiary, please tell us the
following:
where the Company presented the gain of approximately $53
million in its statement
of operations and whether the $53 million is included in the
$61,346 net gain on
investment in Alset International during the unconsolidated
period;
how the $61,346 was calculated and whether such "net" amount
related to the
Company reestablishing control and therefore consolidating Alset
International again;
the facts and circumstances that led to the Company
reestablishing control; and
how the Company considered the guidance in ASC 805 when
considering the
accounting once the Company reestablished control of Alset
International.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Ameen Hamady at 202-551-3891 or Kristi Marrone at
202-551-3429
with any questions.
FirstName LastNameRongguo Wei Sincerely,
Comapany NameAlset EHome International Inc.
Division of
Corporation Finance
June 6, 2022 Page 2 Office of Real
Estate & Construction
FirstName LastName