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I went back and checked; Nope. He posted on Friday and with all this activity, still hasn't clarified. So, until we know exactly what the situation is, here are the answers (BTW, would love to have fully fleshed questions posted; always provide MORE information than you think is necessary; our business is one of nuances and tricky issues): If this is a distribution from an IRA, it is fully taxable and counts for the RMD. If this is a distribution from a church plan, it counts as an RMD, but whether it is taxable is a separate question dependent on the rules for minister housing allowances, a separate issue. The issue is actually simple when boiled down: it's not "is a housing allowance an RMD", it's "is a distribution from a plan (whether taxable or not) counted toward RMD requirements". The answer to that is simple: Yes; the status of the taxation does not affect the application of RMD rules.

The cite is The requirements listed in paragraph (3) include sections 410 and 411. Paragraph (2)(B) has the requirement of substantially full time service for at least a year. Slightly different wording on the IRS website in Publication 7003 which is used to help determine if a plan document meets the requirement of Section 414(n): https://www.irs.gov/pub/irs-pdf/p7003.pdf From page 3: