Respecting whether a private seniors’ residence was a “nursing home,” CRA stated (TaxInterpretations transalation):
[T]he requirement [in S1-F1-C1, para. 1.33] that a facility "offers 24-hour nursing care" would not be satisfied if the establishment offers limited nursing care. This would be the case, for example, where the only nursing care a facility offers its residents is to make available an on-call nurse or where the number of applicable residents does not permit the staff to provide nursing care around the clock.
It may be that the same institution offers several levels of care so that a floor or part of the facility is reserved for residents who are unable to care for themselves and need nursing care 24 hours a day. In such cases, the establishment may qualify as a nursing home with respect to that floor or part of the facility only.