It's the total combination
For the folks who check this thread since it's still good info... If you are running the correct offset wheel (4.5" backspacing), at full wheel lock left or right, a 33" (285) tire will rub on the A pillar frame body mount. If not always depending on the tire, it will on articulation. Doing the frame mod is relatively simple and done properly, will be undetectable by the average person. Done properly, it will also give you room to stuff up to a 35" tire with minor scrubbing.
The OME lift will not give 3" of lift. It's actually 1.75" to 2". When you use OME, you have to make sure the spacer ring is put on the front left shock. Most people don't notice but your FJC will sit a bit crooked if you don't. The FJC is a couple hundred pounds heavier near that corner.
Yes, you can get 3" of lift from coilovers. Don't do it. If you go above 2.5", you place excessive strain on the upper ball joint that can lead to failure. If you want to crank it up to 3", use an after market upper control arm. You'll have little if no droop left in your suspension but you won't break a ball joint.
So if you run the correct back spacing and do the frame modification, you can wheel it hard and not damage the fender.