Sino-Global Shipping America, Ltd.

136-56 39th Ave, Suite 305

Flushing, NY 11354

April 2, 2014

By EDGAR Delivery

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-4631

Attention: Lyn Shenk and Theresa Messinese

Re: Sino-Global Shipping America, Ltd.

Form 10-K for the period ended June 30, 2013

Filed September 27, 2013

File No. 001-34024

Dear Ms. Messinese:

On behalf of Sino-Global Shipping America, Ltd. (the “Company”), we hereby provide responses to the comments raised in that certain letter from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) to the Company dated March 26, 2014. For the Staff’s convenience, we have included the Staff’s comment verbatim above our response.

Form 10-K for Fiscal Year Ended June 30, 2013

Consolidated Statements of Operations and Comprehensive Loss, page F-3 Net Loss Attributed to Non-Controlling Interest

1. We note your response to prior comment 3 that the agreements between Trans Pacific and Sino-China require the non-controlling interest to absorb 100% of any losses incurred. We are unable to locate disclosure in your Form 10-K for the year ended June 30, 2013 or previous filings that states these terms. Please direct us to the appropriate disclosure or agreement filed previously as an exhibit that supports this statement. Also, as it appears based upon the disclosure provided that “substantially all operations and revenues are generated through Sino-Global,” please tell us the nature of the transactions or operations that resulted in the remaining net loss attributable to Sino-Global.

Response: We acknowledge the Staff’s comment and advise that we have consistently applied this consolidation policy since the time of our initial public offering. Indeed, we discussed this question with the Staff during the initial public offering process. As our response to comment 2 in the attached letter to the SEC dated April 9, 2008 discloses, “The non-controlling interest appears to represent more than 10% of total historical earnings. This is due to Sino-China’s general absence of net income for fiscal years prior to June 20, 2006. The control agreements require Sino-China to pay the [Company] a percentage of its net income, but not a percentage of its net losses.” At the time, we advised the Staff that, “[i]n order to clarify [our] consolidation procedures, [we have] added the following language to pages 5, 28 and F-7 [of the registration statement]: ‘We do not receive any payment from Sino-China unless Sino-China recognizes net income during its fiscal year. These agreements do not entitle us to any consideration if Sino-China incurs a net loss during its fiscal year.’”

During fiscal 2013, substantially all of the Company’s net loss was attributable to Sino-Global Shipping America, Ltd. (our parent company for approximately $1.5 million) and Trans Pacific Shipping (our WOFE for approximately $180,000), partially offset by net income of approximately $50,000 from Sino-Global Shipping HK.  The net loss from our parent company was due mainly to $1.6 million of general and administrative expenses and $0.4 million of tax expense, net of gross profit of $0.5 million.  

To help our readers better understand our policy on consolidation and the underlying factors affecting our operating results, we will enhance our discussion of such matters in our future filings. In particular, we will add a sentence following the above-quoted disclosure to read as follows: “If Sino-China incurs a net loss during its fiscal year, we are not required to absorb such net loss.”

The Company is hopeful that the foregoing answer adequately addresses the Staff’s questions and looks forward to answering any further questions the Staff may have. You may contact me or the Company’s attorney, Anthony Basch (804.771.5725), with any further questions. In addition, the Company acknowledges that:

· The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

· Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

· The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,

/s/ Anthony S. Chan

Anthony S. Chan

Acting Chief Financial Officer

Enclosure: Response letter to SEC dated April 9, 2008