Client is a retiring minister, age 63. He inquired about whether he can continue to use the housing allowance to shelter income in retirement. IRS Pub 517 seems into indicate “yes” (see excerpt, below).

However, it is unclear to me whether there are restrictions to this ability based on source of income. Assume a calculation of $20,000 for housing under the definition. For example:
1) If the retiree takes distributions from the ministry 403b plan, does the housing allowance exclusion apply?
2) If the retiree takes distributions from an IRA plan (rollover from ministry 403b plan), does the housing allowance exclusion apply?
3) If the retiree takes distributions from an IRA plan (NOT rollover from ministry 403b plan), does the housing allowance exclusion apply?
4) If the retiree realizes gross income from a taxable investment account (or other non-retirement account income), does the housing allowance exclusion apply?

IRS Pub 517 reads: “Retired ministers. If you are a retired minister, you can exclude from your gross income the rental value of a home (plus utilities) furnished to you by your church as a part of your pay for past services, or the part of your pension that was designated as a rental allowance. However, a minister’s surviving spouse cannot exclude the rental value unless the rental value is for ministerial services he or she performs or performed.”

Thanks for your help!