United States securities and exchange commission logo





                               July 9, 2020

       Samuel Morrow
       Chief Executive Officer
       Scully Royalty Ltd.
       Unit 803, Dina House
       Ruttonjee Centre, 11 Duddell Street
       Hong Kong SAR, China

                                                        Re: Scully Royalty Ltd.
                                                            Form 20-F for
Fiscal Year Ended December 31, 2019
                                                            Filed May 11, 2020
                                                            File No. 001-04192

       Dear Mr. Morrow:

              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 20-F for Fiscal Year Ended December 31, 2019

       Disposition of Non-Core Subsidiaries, page 13

   1.                                                   We note your disclosure
on pages 13, 20 and 21 briefly discussing the disposal of non-
                                                        core metals products
lines and subsidiaries and deconsolidation of certain other non-core
                                                        subsidiaries resulting
in the recognition of gains totaling $2.2 million and $25.1 million
                                                        during the fiscal years
2019 and 2018, respectively. Please revise future filings to provide
                                                        a significantly
enhanced discussion for each sale, disposal, deconsolidation and
                                                        acquisition, as
applicable. Disclosure in future filings should discuss the underlying
                                                        reasons for each
individual sale, disposal or deconsolidation along with quantification of
                                                        the gain or loss
attributable to each of these transactions and detail of the carrying value of
                                                        assets and liabilities
sold for each sale or disposal. In addition, please ensure that your
                                                        disclosures discuss how
these sales, disposals and deconsolidations are expected to impact
                                                        financial performance
(i.e., revenues, cost and expense line items and net (loss) income)
 Samuel Morrow
FirstName   LastNameSamuel Morrow
Scully Royalty  Ltd.
Comapany
July 9, 2020NameScully Royalty Ltd.
July 9,2 2020 Page 2
Page
FirstName LastName
         and trends moving forward.
Business Segments, page 14

2.       We note brief disclosures of proprietary investments made, investments
in equity or debt
         instruments (secured and unsecured), investments in hydro-electric
power plants,
         hydrocarbon production and processing assets, operation of a regulated
specialty trade
         finance and regulated merchant banking business, and an interest in
certain industrial real
         estate in Europe. These disclosures are overly broad and do not
provide an investor with a
         clear understanding of your main revenue generating businesses. Please
revise future
         filings to provide a more transparent description of each significant
product or service
         performed that generates revenue with prominence given to those
products or services
         relative to their contribution to your business. In preparing your
disclosures, please
         address the principal geographical markets and customers served and
provide a detailed
         understanding of the businesses and investments included in each
segment. Refer to Item
         4.B of Form 20-F.
Results of Operations, page 18

3.       We note your disclosure on page 19 that revenue for your Industrial
Equity segment
         decreased primarily as a result of the disposition of metal product
lines. We also note
         your disclosure that revenue for your Merkanti Holding segment
increased primarily as a
         result of additional merchant banking activities. Please revise future
filings to describe
         these fluctuations in revenue with a significantly enhanced discussion
of the metal lines
         that were disposed of, the underlying reasons for the disposals, and
the additional
         merchant banking activities that were provided. In addition, please
revise future filings to
         remove terms such as    primarily    in favor of specific
quantifications and describe how the
         dispositions and additional merchant banking activities are expected
to impact financial
         performance and trends going forward. Refer to Section III.D of SEC
Interpretive Release
         33-6835.
Financial Statements
Notes to Consolidated Financial Statements
Note 2. Basis of Presentation and Summary of Significant Accounting Policies
 Revenue
Recognition, page 73

4.       We note your existing disclosures describing your revenue recognition
policy are broad
         and appear to provide disproportionate prominence to products relative
to their
         contribution to your business. In this regard, we note your disclosure
on pages 5 and 18
         that approximately 89% of total fiscal year 2019 and 2018 revenue
related to merchant
         banking products and services with the majority of revenue in fiscal
year 2019 derived
         from the sale of products, which include metals, hydrocarbons, food
products and other
         materials. Further, we note your disclosure on page 19 that your
proportionate revenue by
         product from metal processing was 80% and 88% in fiscal year 2019 and
2018,
 Samuel Morrow
FirstName   LastNameSamuel Morrow
Scully Royalty  Ltd.
Comapany
July 9, 2020NameScully Royalty Ltd.
July 9,3 2020 Page 3
Page
FirstName LastName
         respectively. In future filings, please revise your disclosures to
focus on the most
         significant revenue generating activities followed by a discussion of
the less prominent
         activities in a context that clearly indicates the relative
materiality of the revenue stream.
         In preparing your disclosures, please discuss the following:

                The specific products or services associated with these sales
and metal processing;
                Identification of the customer(s);
                The specific transaction(s) that comprise the earnings process
and at what stage
              revenue gets recorded; and
                Whether there are any material customers that comprise a
substantial portion of
              revenue.
Note 2. Basis of Presentation and Summary of Significant Accounting Policies
 Interests in
Resource Properties and Reserve Estimates, page 81

5.       We note that your disclosures surrounding your interests in resource
properties on pages
         29, 70, 81 and 93-94 focus more on hydrocarbon properties despite the
fact that your
         interests in resource properties is mainly comprised of an interest in
an iron ore mine. In
         order to provide proportionate prominence to the relative contribution
to your business,
         please revise future filings to provide an enhanced discussion of your
interest in the iron
         ore mines and include the following:

                Describe the determination of cash-generating units ("CGUs") as
it relates to your
              interest in iron ore mines, including an explanation as to what
the CGUs represent;
                Discuss all of the CGU-specific facts and circumstances
considered when you assess
              whether there is an indicator that an impairment of your
interests in iron ore mines
              may exist (Refer to paragraphs 12-14 of IAS 36 for guidance);
                Describe, in detail, how you estimated the recoverable amounts
associated with your
              interests in iron ore mines, specifically stating whether you
estimated the fair value
              less costs to sell or the value in use or both, along with the
material estimates and
              assumptions made (Refer to paragraphs 18-57 and 74-79 of IAS 36
for guidance);
              and
                For both of your interests in hydrocarbon properties and iron
ore mines, to the extent
              that it is reasonably possible a future impairment charge could
be recognized, discuss
              the facts and circumstances that could lead to future impairment
charges. Please also
              discuss the facts and circumstances that could lead any future
reversals of impairment
              charges previously recognized. To the extent material, please
disclose the cumulative
              amount of impairment charges recognized as of the end of the most
recently
              completed balance sheet that are subject to reversal.
6.       We note your disclosure on pages 29 and 81 that the recoverable
quantities of reserves and
         estimated cash flows from your hydrocarbon interests are independently
evaluated by
         reserve engineers at least annually. Please revise future filings to
specify, whether you
         obtain similar independent evaluations related to your interest in
iron ore mines. If not,
 Samuel Morrow
Scully Royalty Ltd.
July 9, 2020
Page 4
         please explain the underlying reasons for obtaining them for
hydrocarbon interests but not
         iron ore mines.
       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 John Spitz, Staff Accountant, at (202) 551-3484 or Ben
Phippen, Staff
Accountant, at (202) 551-3697 with any questions.



FirstName LastNameSamuel Morrow                               Sincerely,
Comapany NameScully Royalty Ltd.
                                                              Division of
Corporation Finance
July 9, 2020 Page 4                                           Office of Finance
FirstName LastName