I'm not sure what you mean by "pass-through dividends." Are you asking about distributions paid to you form company stock held in your company retirement account, reported with code U in box 7 of a Form 1099-R? No these are not regular distributions. Code U distributions are ESOP dividend distributions which are not subject to early-distribution penalty and are not eligible for rollover. If you are subject to RMDs, code U distributions do not satisfy any part of your RMD.
