Yes he is. Proof: Madara is Juubi Jin. Juubi can die by sage power. TSB is a sage power. It's black and Zetsu's black and they both are made of sage power. Therefore, he is TSB.
No but seriously, he called Kaguya his mother. The only ability that can create him is the Creation of All Things. And he's likely not meant to use ninjutsu anyway; plus, I can't see the relationship between him not using ninjutsu and TSB cancelling them out. Otherwise, he would have the ability to erase non Sage enhanced ninjutsu.
No, he is not a TSB.