Justin Bender and I have just completed the second edition of our popular white paper, Foreign Withholding Taxes: How to estimate the hidden tax drag on US and international equity ETFs.
Originally published in 2014, the paper explains how many countries impose a tax on dividends paid to foreign investors—most notably a 15% levy on US stocks held by Canadians. When the first edition appeared, foreign withholding taxes were not well understood by many investors and advisors, and even the ETF providers rarely discussed them. In the two years since, the issue seems to be getting more recognition. Both Vanguard and iShares, for example, have made changes to their international equity ETFs to make them more tax-efficient. That’s great news, though it also made the first version of our paper somewhat dated.
In this new edition, we’ve made some significant changes. First, we’ve removed corporate accounts from the discussion and focused on personal accounts only. We’ve also used some different ETFs in our examples, including the Vanguard U.S. Total Market (VUN), the Vanguard FTSE Developed All Cap ex U.S. (VDU) and the iShares Core MSCI EAFE IMI (XEF). Finally, we’ve added some additional commentary to help investors make better decisions.
The takeaways
We invite you to dive into the paper for all the details, but if you’re looking for a summary of the important points, here they are:
- In an RRSP, using US-listed ETFs for foreign equity holdings can bring a significant tax advantage. That’s because these securities are exempt from the usual 15% withholding tax on dividends imposed by the US government. Assuming a 2% yield on US stocks, the tax savings amounts to 0.30%.
. - In taxable accounts, Canadian-listed ETFs are generally a better choice. US-listed ETFs offer little or no tax advantage, and in cases where there would be a small benefit it’s likely to be outweighed by other considerations, including currency conversion costs and additional record-keeping—more on this below.
. - In a TFSA or RESP, you should always use Canadian-listed ETFs for foreign equities. US-listed ETFs offer no tax advantage whatsoever, and in some cases they’re significantly less tax-efficient.
. - Finally, if you use Canadian-listed ETFs for international equities, look for funds that hold the stocks directly rather than through an underlying US-listed ETF. The “wrap” structure imposes a second level of foreign withholding tax that is not recoverable. To review the example we use in the paper, XEF holds its stocks directly, and Justin estimated its tax drag at 0.26% in an RRSP or TFSA. By comparison, VDU gets its exposure via an underlying US-listed ETF, resulting in foreign withholding taxes of 0.59%. (Note that Vanguard’s newer international equity fund, VIU, holds its stocks directly, so its tax drag should be similar to that of XEF.)
Understanding the trade-offs
US-listed ETFs have long been popular with Canadian investors because of their low fees, and if you’ve read through our paper you’ll understand they can also have significant tax benefits. With our clients, we regularly use US-listed ETFs in RRSPs and other retirement accounts for these reasons. But with DIY investors we usually don’t recommend this, unless you can be sure you understand the trade-offs. As for taxable accounts, the case for using US-listed ETFs is even weaker. Here’s why:
The cost of currency conversion. Any benefits from the lower fees and taxes on US-listed ETFs will be reduced or even eliminated if you fail to avoid the potentially high cost of converting currency before purchasing them. In most cases you should have a source of USD income or be comfortable using Norbert’s gambit—otherwise, stick with Canadian ETFs.
Here’s a bit of good news from our findings, which Justin explained in more detail in a recent blog. It turns out that in an RRSP, the foreign withholding taxes on XEF, a Canadian-listed ETF, are almost exactly the same as those of its US-listed equivalent, the iShares Core MSCI EAFE (IEFA). So this is one place where you really don’t need to use a US-listed fund.
Record-keeping and reporting. In taxable accounts, tracking the adjusted cost base of US-listed ETFs is significantly more difficult, because you will need to look up the exchange rate on the settlement date of every transaction. This adds an additional cost, especially if you pay a tax preparer to do it for you.
US-listed ETFs are also considered foreign property by the Canada Revenue Agency, and non-registered holdings with a book value of $100,000 CAD or more must be reported annually using the T1135 form. Additional reporting is required when the total cost of your US-listed ETFs is over $250,000 CAD.
US estate taxes. Granted, this isn’t a problem for most of us. But wealthy Canadians may be subject to US estate taxes if they have significant holdings in US-listed ETFs, even if these are held in an RRSP.
“Additional reporting is required when the total cost of your US-listed ETFs is over $250,000 CAD.”
Total cost of unregistered US-listed ETFs or total cost of all US-listed ETFs ?
And I should have started off with : very interesting blog entry that I’ll want to refer to repeatedly. Thank you.
@Paul G: The T1135 only applies to US securities held in non-registered accounts:
http://www.taxtips.ca/filing/foreign-asset-reporting.htm
Just to be clear, about the T1135, Canadian versions of US funds (like for example VFV) held in a non-registered account with a book value over 100k don’t need to be reported, correct?
Great article and white paper! I’ve referred back to your other articles about withholding (geez it’s weird writing a word with two consecutive h’s) taxes several times and they are such a valuable resource for Canadians to make asset allocation/location decisions.
Thanks!
Great article. I wish this kind of clear, useful information was available more widely (looking at you, discount brokerage websites).
You mention ETF wrap structures a fair bit-how can I find out the structure of a particular ETF? It doesn’t seem to be immediately obvious on the companies website. Cheers.
Thanks Dan, I was eagerly waiting for you to write about these changes!
Great article and a really useful paper. The original, I think, was an eye-opener for a lot of people I something I know I referred to a lot to craft my portfolio.
The Excel junkie inside me has had visions of crafting some grand Excel “optimizer” spreadsheet that would take into account FWT, plus MERs, plus tax on the distributions themselves, compare it against my various account sizes, and automatically compute the most efficient fund and asset location on an all-in basis. Each time I get a little bit into it, then my boss (or wife) tells me to stop that. :)
That said I think you can distill it down to a few simple logic points:
1) From a (distribution) tax perspective, TFSAs aren’t great – worst choice for any type of equity. The least bad choice is to put your EAFE equity (XEF) or US equity (VTI/VUN) in there. Try not to use it for Emerging Mkt equity.
2) Other than that you have a “good choice” just about everywhere else (ie it’s “optimal” to store any kind of equity in RRSP or Unregistered accts)
3) I wonder how long until somebody creates a Type H fund that holds emerging market stocks directly?
@Adam C: Correct: the T1135 is only required for US-listed ETFs only, not Canadian-listed ETFs that hold US stocks (like VFV).
@Michael: This is explained in the white paper. The info is on the websites and in the funds’ annual reports, though it is not necessarily obvious.
@Willy: Regarding your last comment, the BMO emerging markets ETF is close: it holds many of the underlying stocks directly and supplements these with some ETFs. Trading in emerging markets is expensive, so it may actually be cheaper overall to take advantage of the dramatically reduced trading costs of the wrap structure even if the withholding taxes are higher.
Great article. Was hoping for an expanded appendix simply stating the total cost of various ETFs, especially XAW vs VXC, particularly since you (https://canadiancouchpotato.com/2016/06/20/cost-versus-convenience-in-ex-canada-etfs/, “the total cost of VXC in a retirement account is 0.71%, compared with just 0.19% for the US-listed ETFs”) and Justin (http://www.canadianportfoliomanagerblog.com/war-of-the-worlds-ex-canada/, “After taking into account the additional tax drag from foreign withholding taxes, the estimated cost of VXC increases to 0.66% (from 0.27%)”) appear to give different estimates for VXC. Maybe the disagreement is the reason it was kept out of the paper?
Could we consider VXUS as being roughly 2/3 VEA and 1/3 VWO for withholding tax calculations ?
Since it used to be in your model portfolios, I’m sure many of us build our personal portfolios with it as a core holding.
As per Gavin’s comments, could you please elaborate on implications for VXC?
I built my portfolio with VXC, but as portfolio grows that tax drag on VXC is going to get noticeable. At what portfolio size does hassle of norbert’s gambit start to make sense? Any chance Vanguard could start holding stock directly, as it now does in VIU?
To be clear, I meant “could start holding stock directly in VXC”.
Great, post, btw. Thanks!
Thanks for an interesting white paper.
It says that for all account types, a Canadian-listed ETF that holds international stocks directly — not via a U.S.-listed ETF — is more tax-efficient. In the case of taxable accounts, is this because of Level 1 tax? (The paper notes that in some ETF categories — e.g. D & G — Level II tax is recoverable for taxable accounts.)
I think the information is wrong for VEE. It is reported as holding a US ETF, while in fact it is holding the stocks directly, so likely more tax efficient than the others. Thoughts?
@Gavin: Foreign withholding taxes in funds like XAW and VXC (which hold a mix of US, international and emerging equities) can only be estimated based on the dollar amount paid by the fund over a given period. That’s why Justin got two different numbers when looking at VXC at two different times. A few basis points of difference does not mean much. In general, XAW should be somewhat more tax-efficient because it holds its international stocks directly, while VXC uses an underlying US-listed ETF. However, for the US and emerging stocks both ETFs are roughly equivalent.
@alf: I think the portfolio needs to be at least six figures before you start worrying about using US-listed ETFs in your RRSP, and even then, it depends on your comfort level with Norbert’s gambit. I would not expect VXC to hold stocks directly any time soon: if anything they might one day hold international stocks via VIU.
@Mike F: Yes. Only the last level of FWT is potentially recoverable in a non-registered account. So if Level I is the only one that applies (as in Type E), then that is recoverable. But if Level I and Level II both apply (Type D and G), only Level II is recoverable.
@Legato: VEE does not hold its stocks directly: it holds VWO. Admittedly this is not obvious, though the web page does say “Invests primarily in the U.S.-domiciled Vanguard FTSE Emerging Markets ETF.” iShares is a little more upfront about this because it lists the US-listed ETFs in its holdings, rather than listing the underlying stocks.
Hi Dan,
Great article – much appreciated.
Would you consider selling VDU or VEE within an RRSP to move to XEF or XEC? I assume that if it’s
in an RRSP there’s no tax related to capital gains (both have risen in value).
What about a negligible gain within a taxable corporate account (0.5% for VDU, 2.5% for VEE) ?
Ie. at what percentage gain or dollar value gain would the sale within a taxable account not be worth
the savings in withholding taxes?
hi Dan, and Justin
great info as usual. Question, which may be beyond scope so feel free to refer me elsewhere, the paper continually refers to the Level1 tax being recoverable in a taxable account. is this really recoverable, or is is only as i read it a tax credit against other income taxes owed in Canada, therefore if you have income less than basic exemption you have no way to recover.
@François: Yes, you are correct. The FWT is only recoverable if you actually pay tax. Our general assumption is that people who pay no tax are unlikely to have significant non-registered investments.
Hi Dan,
I’m surprised to read that XAW holds its stocks directly. When looking at https://www.blackrock.com/ca/individual/en/literature/fact-sheet/xaw-ishares-core-msci-all-country-world-ex-canada-index-etf-fund-fact-sheet-en-ca.pdf it seems that its holding are a mix IVV, XEF, IEMG, IJR and IJH.
@Hyacinthe: This is true, but XEF is a Canadian-listed ETF that holds its stocks directly. In terms of foreign withholding taxes the “wrap” structure has no effect in the case of one Canadian-listed ETF holding another Canadian-listed ETF, so XAW behaves as though it held its international stocks directly.
Oops, my mistake. Vanguard is not very clear on the way they list stuff. As you said, VEE actually holds VWO, but on the page, they list all the underlying stocks from VWO, instead of VWO itself…
Truly great stuff Dan,
This is very valuable information that the vast majority of financial advisors would have absolutely no clue about. We are all grateful for the information you Justin continue to feed us for free!
I have a question regarding the structure of the new vanguard “active” (aka smart beta) funds including VLQ, VVO, VMO, and VVL. To me these global versions seems of factor tilts seem like a clean simple way to tilt your portfolio. I have been trying to determine if these are wrapped or directly held. I know there is a reference I your fabulous white paper explaining where you found the true underlying funds for other Vanguard funds but there does not yet appear to be an equivalent document for these funds yet.
Just curious if you know the structure.
Thanks again.
Dan, could you please give more details on how to recover US witholding tax? I guess it’s through your income tax but I’m not familiar with the procedure. Thanks a lot for your help!
I used to spend more time worrying about the em witholding tax but I still prefer to have an equity etf with high growth potential in a tax sheltered account. Saving 40 basis points is good but saving 2.6 -3.5% capital gain is better. https://canadiancouchpotato.com/2016/03/21/what-returns-to-expect-when-youre-expecting/
Can someone explain the concept of withholding taxes for a beginner with examples? How does it work?
For example, funds like VUN, XEF, VEE are foreign funds held by Canadian companies (I think). Does withholding tax apply to them?
Or, in terms of tax implication, what is the difference between VCN and VUN, XEF or VEE?
Thanks
@Shaun: Thanks for the comment. I agree it’s not clear what the strategy is for the new Vanguard factor ETFs. An email to Vanguard should answer the question for you. There does not seem to be US-listed versions of these ETFs, so my guess is they are not “wrap” products.
@Phil: If you are filing your taxes correctly you’re probably already doing this without noticing. Your T3 and T5 slips have a box for “foreign tax withheld.” You enter these amounts when you input all the information on your T slips and the credit is applied automatically.
Hi Dan,
Thank you so much, great work! It seems like buying US ETFs does not have any sense in TFSA. Any suggestions to use US dollars in TFSA account? I know about Norbert’s Gambit but can I benefit buying some ETFs on Toronto Stock Exchange for US dollars?
Can you guys update the corporate section of the white paper separately, too? Some of us invest corporate funds too. Thanks in advance for the great info!
SNB
@Sharukh: The issues in corporate accounts are much more complicated than in personal accounts and we decided not to muddle the issues in this version of the paper. Justin is working on a blog with more information that I think you will find helpful; we may even do a white paper on this subject in the future. In general we suggest avoiding US-listed ETFs in corporate accounts because of the additional recordkeeping and reporting requirements. Moreover, it usually makes sense to hold Canadian equities in corporate accounts and US and international equities in personal accounts where possible, but this is not a foreign withholding tax issue specifically.
@Henry: You are correct that it is best to avoid US-listed in ETFs in TFSAs altogether. But are you saying you have USD cash in your TFSA and are looking to invest it? I suppose you could us USD-denominated ETFs that trade on the TSX (there are a few) but I would probably lean toward converting the currency or withdrawing it from the TFSA and replacing it with Canadian cash.
Hello,
I hold the following USD investments in my corporate account:
– Vanguard Total Stock Market ETF (VTI)
– Vanguard Total International Stock ETF (VXUS)
In hold the following USD investment in my RRSP:
– Vanguard REIT ETF (VNQ)
In hold the following CDN investment in my TFSA:
– FTSE Canada All Cap Index ETF (VCN)
I’ve been doing this since 2012 after checking with various sources online (i.e. message boards and similar blogs – but never with a financial planner). However, I noticed that one of your comments said “… we suggest avoiding US-listed ETFs in corporate accounts because of the additional recordkeeping and reporting requirements. Foreign withholding taxes are only partially recoverable in corporate accounts, so it often makes sense to hold Canadian equities in corporate accounts and US and international equities in personal accounts where possible.”
I have an accountant do my taxes every year so I’m okay with the recordkeeping and reporting requirements. However, I’m just checking in with you on the withholding taxes part. Is my investment strategy still optimal from a tax perspective?
Thanks
@Mike: I reworded my comment to avoid the term “partially recoverable,” which wasn’t the best choice of words. In general terms, the foreign withholding tax issues are similar in corporate and personal accounts. The more important issue has to do with the “dividend refund mechanism,” which doesn’t work as well for foreign-source income as it does for Canadian-source income. So in your case, whether you use VTI/VXUS or Canadian-listed ETFs in the corp makes no difference in terns of foreign withholding taxes. But in general it may makes sense to keep US and international equities in an RRSP and hold more Canadian equities in the corp. We’ll try to write more about these questions in the future.
Thanks for this great paper.
I am however urged to point out these two important points… they apply to US taxpayers living in Canada.
1) CAD ETF and MF are considered PFIC’s by the IRS and are subject to very unfavorable tax treatment. The only exception is if you are holding them inside a RSP or RIF. If on an RESP and TFSA, let alone an unregistered account, you simply should not own CAD ETF or face very unfavorable tax treatment.
2) I am confused whether all these withholding apply to USA citizens who filled out properly a W9 form when opening their account. I never saw tax taken out on my RESP account and I presume that it is not taken out. in that case I guess we should worry only about level II tax WH. Am I correct?
Thanks again
@CCP
Dan,
I got a reply from Vanguard regarding their new global factor ETFs (VLQ, VVO, VMO, and VVL):
“The ETFs hold the securities directly, vs wrapping a US listed ETF.
We are not allowed to show performance/holdings right now due to regulatory requirements – however we do offer these products in the UK so if you go to the UK website you will be able to view the holdings.”
So you were correct in your guess.
Thanks
Just adding to my comment above, pending the reply from the big boss, that I checked with my QT broker and indeed there is no WH at all for a US person submitting a W9.
Also, many Vanguard and iShares ETF are providing a PFIC statement thus mitigating the bad rap for CAD listed ETF’s for US persons.
If all this is right, it would mean that for US person the only thing to worry about is the WH of level II kind. Awaiting little clarification to see if I am right
Thanks in advance
@Abe: I am not an expert in cross-border tax issues. However, I did indeed notice that ETF providers are getting better at providing PFIC reports, which is good news. This may be of interest:
https://canadiancouchpotato.com/2014/06/18/us-investors-in-canada-what-to-watch-for/
To clarify, whether you are US person would not affect Level I or Level II if you hold Canadian-listed ETFs (as you could in your RRSP). For example, if you held VUN you would pay the same Level I withholding tax as anyone else. This is applied at the fund level, so filling out the W9 would not spare you. (With Canadian-listed ETFs in registered accounts you won’t ever see these: they don’t appear on your statements or on T-slips.)
If you’re confident that there is no US withholding tax on US-listed ETFs in TFSAs and RESPs, then it would follow that Level I withholding tax would be lost on international equities (this is levied by the countries where the stocks are domiciled) and Level II (levied by the US) would not apply.
Since hxs is tax friendly and has no dividend, it should be a good alternative stock for taxable and resp?
What does hxs do with the dividend? Is it applied to give lower MER?
Thanks for your fast reply!
I would humbly propose that in a future edition of the paper you add another level… to distinguish between US taxes withheld as level I on the fund level (which are not abated by filing a W9) and the ones withheld directly from the client (abated by the W9). It makes a world of difference and changes all the equations in your nice paper. For sure there are no US WH on direct dividends in any kind of plan, though there is of course the indirect dividends at the fund level as you mention.
More directly in my case, I have a RESP and a RRSP. my main consideration was the PFIC issue which only affects RESP but not RRSP. I thus had my entire RESP in US listed ETF with all diversification done thru them, while having CAD Couch potato portfolio on the RRSP. I am comfortable doing Norbert gambit and thats how I invest but the process is a little cumbersome and takes time.
Seeing that both iShares and Vanguard started giving the PFIC info, the onerous tax treatment is no longer there, except for the burden of the form filling etc which is done by a pro anyway. So I would for the sake of our argument consider the PFIC issue now a wash with the inconvenience of having to gambit each monthly distribution for the USD ETF. essentially removing them both of the equation.
I am now confused whether you would in my case still stick to the recommendation of having USD ETF inside my RESP. I sure understand that I should change my RSP to US ETF. In other words, I am unable to apply your recommendations in the paper to my case.
I know you can’t give personalized advice… I am betting my question is quite general in the sense that it applies to the millions of US persons living in Canada. I will really appreciate your help in sorting that out for me.
Thanks in advance
Another unrelated question.
Do you have anywhere a model portfolio for USD ETF? that is mirroring the couch potato but with USD listed ETF equivalent?
@Joe: In most cases HXS doesn’t help with the withholding tax issue. Its “swap fee” of 0.30% essentially washes out the advantage of avoiding the withholding tax on dividends. It might still be a tax-efficient choice in a non-registered account, but it doesn’t help much in an RESP or other registered account.
@Abe: I explored the idea od USD Couch Potato a while back, though not with an eye to US persons and their unique tax considerations:
https://canadiancouchpotato.com/2013/03/26/ask-the-spud-the-us-dollar-couch-potato/
In general, I would look at holding Canadian-listed bond ETFs in RRSPs and a couple of US-listed Vanguard or iShares ETFs for equities in taxable accounts. Something like VT or ACWI covers the whole world with a single fund, effectively replacing VXC or XAW. If you want to add more Canada there are US-listed options such as EWC, but if you’re comfortable with the PFIC issue you could just use a Canadian-listed fund here. And if you need to hold fixed income in non-registered accounts, GICs would allow you to keep the funds in CAD and avoid any concerns about PFICs.
The RESP question is difficult, because many tax experts recommend that US persons not hold RESPs at all (nor TFSAs, for that matter). I don’t feel qualified to weigh in on that question except to say that if it’s possible to avoid it (e.g. opening the RESP in the name of a spouse who is not a US person) then that’s the safest bet.
Sorry for being persistent… if I may try once more…as I am still unclear.
the tax implications in terms of filings and other reporting issues I studied myself. I know about the issues with RESP and TFSA and the like. In my case it was worth to have an RESP despite all that and not heold TFSA. Its not there where my question is. assuming I already have the RSP and RESP and only deciding strivly on account of the WH issue where to place my investments.
In a nutshell, I would ask you to confirm only the following point to make sure I understand your position.
1. Given that the main problem of holding USD ETF’s inside an RESP (i.e. your type A funds) is because of the direct withholding that is not recoverable, this would not be applicable to W9 filers. In effect making the RESP W9 filer similar to the regular Canadians RSP., meaning that USD ETF would be recommended.
2. Types C and E funds, which are effectively indifferent for RRSP’s (both have unrecoverable level I tax but not level II tax from the US, although the type E tax is somewhat higher due to different treaties) would be the same for W9 filers RESP’s. Again making the type C recommended.
I can summarize my question even further… Do i correctly assume that for a W9 filer the RESP would be the exact same as the RSP?
By the way, will Canada not charge withholding tax on the dividends paid to EWC at the fund level?
Looking forward to more info on investing in corporate accounts!
@Abe: I am not a specialist in cross-border tax issues and cannot answer your questions more specifically than I already have.
What are the chances that in the future the TFSA is included in the canada/us tax treaty as a registered account and the witholding tax acts like RRSP? Do these treaties ever get updated or renewed? How do we help the process get started? thanks!
@ papa whiskey tango
I hope they do not do that. Having the USA treat TFSAs as a retirement account for tax treaty purposes would likely require that Canada impose retirement account restrictions on a TFSA, like a Roth IRA has penalties for withdrawing investment earnings before age 59.5, and maxim income limits to contribute.
Dan / Justin, thanks again for sharing this amazing info with us. I had a few questions/comments:
1. I found it surprising that in an RRSP for developed markets international stocks (ex US), it’s more advantageous to hold a US-listed ETF rather than a Canadian listed ETF that holds international stocks directly. Is that because the tax treaties established by the U.S. with various developed countries are better than those established by Canada? In the white paper, VEA (US-listed) had 4.98% withholding tax level 1 and XEF (CDN-listed) was 8.04%. This resulted in costs of 0.16% for VEA and 0.26% for XEF. Regardless, given the lack of a CDN-listed fund holding developed AND emerging intl markets directly, I’ll continue to hold VXUS in my RRSP. If someday that CDN-listed fund comes along, I would likely consider holding it directly to avoid doing Norbert’s Gambit for VXUS.
2. Are there any Canadian-listed ETFs that hold a diversified set of US stocks directly? I noticed this scenario is not included in your white paper.
3. For Vanguard Canadian-listed ETFs, how can you tell whether they hold stocks directly or hold a US-listed ETF? For example, VXC from your model portfolio holds 4 US-listed ETFs directly: VV, VGK, VPL + VWO (based on your articles), but when I check their site, https://www.vanguardcanada.ca/advisors/mvc/detail/etf/overview?portId=9548 , it makes no mention of those ETFs. In your white paper, you say to look at the “Statement of Investments section in the fund’s annual report”, but I don’t see that on their webpage.
Thanks again!
@Troy: Thanks for the comment.
1. Yes, the US and Canada have different tax treaties with overseas countries, and that explains part of the difference between VEA and XEF. However, IEFA (which tracks the same asset class) has a number much closer to XEF, so it is hard to know exactly why these differences appear.
2. There are several Canadian-listed ETFs that hold US stocks directly, but this has no impact on foreign withholding taxes.
3. On Vanguard ETF webpages, click “Show more” under the heading “Documents” on the right hand side. The “Annual MRFP” has this information.
@Dan Thanks for the replies!
For #2. In my RRSP, I hold VTI as my US holding. To avoid having to do Norberts Gambit and invest smaller amounts, it would be nice to instead hold a Canadian-listed ETF that holds US stocks directly since they have mostly the same withholding tax rate. So any suggestions there would be appreciated. It will obviously be hard to compete with VTI’s MER though.
For #3. Thanks! I was searching the PDF for VGK and couldn’t find it, but I now see they list the name instead “Vanguard FTSE Europe ETF”.