Taxpayers managed residences (governed by the Quebec Act respecting health services and social services) for the disabled or the elderly who wished to have their income exempted under s. 81(1)(h). The Directorate indicated:
- provided that the program made payments on the basis of a means, needs or income test, there was no need to perform a separate calculation of the needs of each beneficiary under the program;
- the “principal place of residence” test would not be satisfied if the program beneficiaries stayed in an adjoining residence, for example, the second unit in a duplex;
- an amount paid that was called an honorarium to a foster home could constitute a social assistance benefit; and
- it was permissible for the homeowner to generate a profit, which would be viewed as compensating the homeowner for the care and services provided to those beneficiaries and, therefore, as amounts received for the benefit of those beneficiaries.