Individuals to whom subsection applies
This subsection shall apply to an individual for any taxable year if—
(A)#
the entire amount of such individual’s gross income for the taxable year from sources without the United States consists of qualified passive income,
(B)#
the amount of the creditable foreign taxes paid or accrued by the individual during the taxable year does not exceed $300 ($600 in the case of a joint return), and
(C)#
such individual elects to have this subsection apply for the taxable year.