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.