Interesting question. I doubt it because the ETF is almost certainly a US-company. (Assuming you are a US citizen or US resident.) But I don't know enough to give you a clear answer. Perhaps something lets like a pass-through could be in play here.
(a) sales of personal property (i.e. not real estate) by a US citizen are US source income unless an exception applies as described the rest of section 865.
So you have to find an exception that applies if you want it to be foreign source income.
Do you have other foreign tax paid so that you want more income for the I.R.C. 904(a) proration calculation?
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