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Page 18 of Pub 514 ( on the subject of whether the safe harbor amount exists)
Exemption from foreign tax credit limit.
You will not be subject to this limit and will be able to claim the credit without using Form 1116 if the following requirements are met.
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Your only foreign source gross income for the tax year is passive category income. Passive category income is defined later under Separate Limit Income. However, for purposes of this rule, high-taxed income and export financing interest are also passive category income.
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Your qualified foreign taxes for the tax year are not more than $300 ($600 if married filing a joint return).
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All of your gross foreign income and the foreign taxes are reported to you on a payee statement (such as a Form 1099-DIV or 1099-INT).
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You elect this procedure for the tax year.
If you make this election, you cannot carry back or carry over any unused foreign tax to or from this tax year.
This election exempts you only from the limit figured on Form 1116 and not from the other requirements described in this publication. For example, the election does not exempt you from the requirements discussed earlier under What Foreign Taxes Qualify for the Credit..
