No. But you can claim it, as long as he is the beneficiary of the 529 plan that you are the owner of. He does not need to be your dependent for the distribution to be qualified for the earnings exclusion.
For 529 plans, there is an “owner” (usually the parent), and a “beneficiary” (usually the student dependent, but it doen't have to be). The "recipient" of the distribution can be either the owner or the beneficiary depending on who the money was sent to. When the money goes directly from the Qualified Tuition Plan (QTP) to the school, the student is the "recipient". The distribution will be reported on IRS form 1099-Q.
The 1099-Q gets reported on the recipient's return.** The recipient's name & SS# will be on the 1099-Q.
You are correct, off campus housing cost is limited to the amt. for a dorm room, for the deduction.
**Alternatively; you can just not report the 1099-Q, at all, if your student-beneficiary has sufficient educational expenses, including room & board (even if he lives off campus) to cover the distribution.
