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And the clear answer is "yes" the distribution used for a housing allowance can do double duty. The fact it is not taxable is irrelevant.

IRA? It’s my understanding that housing allowance treatment does not apply to an individual IRA, so it seems more likely the question is regarding a 403(b) or qualified plan.

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.

Did the OP say we were talking about an IRA?

https://ttlc.intuit.com/questions/4232259-how-do-i-enter-minister-s-housing-allowance-as-a-retired-minister-when-i-do-not-receive-a-w-2-form It is my understanding Rev Ruling 75-22 allows under the correct conditions the retirement plan payment to be a non-taxable housing allowance. See link above. I can't cite anything but I don't see why such a payment doesn't meet the RMD requirement. I have always understood an after-tax (not Roth) distribution can satisfy an RMD requirement. Or at least the part that typically is non-taxable since most after-tax distribution have a mix of both taxable and non-taxable.