answer this: if oro had died, would you still count him with his arms in VS fights???
do you count oro with his zetsu body in a VS fight??
If Orochimaru had died, then no, you wouldn't count him.
The big twist is, he
didn't die.
Is Orochimaru /w Zetsu dead? No, he harbored his soul inside of a Zetsu body before the Reaper can take it. That didn't happen with Minato.
If Minato managed to complete RDS
without dying, but still keeping Kyuubi, then you can count alive Minato as a Jinchuriki.