When the Strait of Hormuz closed in early March, Canadian energy and gold mining equities began a three-month repricing. WTI crude moved from roughly $65/bbl pre-conflict to above $110/bbl at the peak in mid-May before pulling back to approximately $96.60 Tuesday on Hormuz deal optimism. The TSX Capped Energy Index gained more than 40% from its pre-war baseline before this week's reversal. Gold moved from approximately $2,900 USD/oz pre-conflict to above $4,700 USD/oz at the January record high, and is currently trading near $4,523 USD/oz.
For clients who hold these positions outside registered accounts -- in non-registered portfolios or inside corporate investment accounts -- the accumulated gains are substantial. The question the Iran MOU raises is not whether to sell. It is whether clients have thought deliberately about which accounts those gains sit in, what the inclusion rate implications are, and whether the planning window is as wide as it appears.
The Inclusion Rate Arithmetic for Individual Clients
The capital gains inclusion rate change that took effect June 25, 2024 created a two-tier structure for individuals. Annual realized capital gains below $250,000 continue to be included in income at the one-half rate. Gains above $250,000 in a single calendar year are included at the two-thirds rate. For a client who has concentrated energy or gold mining exposure in a non-registered account and who has not yet realized any gains in 2026, the $250,000 threshold may be the most important number in their near-term tax planning.
The arithmetic is not complicated. A client who holds $600,000 in unrealized gains across Suncor, Canadian Natural Resources, and Wheaton Precious Metals in a non-registered account, and who realizes all of it in one calendar year, faces the two-thirds inclusion rate on $350,000 of those gains. Staggering realizations across 2026 and 2027 -- to keep each year's gains below the $250,000 individual threshold -- changes the effective tax cost materially.
Illustrative tax cost on $600,000 in capital gains across four scenarios at a 53.5% Ontario combined marginal rate. The CCPC carries no $250,000 threshold -- the two-thirds rate applies from dollar one. The split-year individual strategy saves approximately $22,000 relative to realizing all gains in 2026.
The chart above illustrates the tax cost differential across four scenarios on a $600,000 gain at Ontario's combined marginal rate. The CCPC column is the one most advisors' incorporated clients are least prepared for.
The CCPC Account: No Threshold Protection
For clients who hold appreciated energy or gold positions inside a Canadian-controlled private corporation, the two-thirds inclusion rate applies from the first dollar of capital gains. There is no $250,000 threshold for CCPCs. This matters because a meaningful segment of high-net-worth clients -- incorporated professionals, business owners, physicians, dentists -- hold investment portfolios inside their corporations as part of a tax-deferral strategy.
The war premium has been generous to those portfolios. A CCPC that bought Canadian Natural Resources in January at $42 and watched it run to $58 before this week's pullback to $49 has an unrealized gain that, if realized, faces the two-thirds inclusion rate at the corporate level. The after-tax cost of that gain is higher than the client may intuitively assume, particularly if they compare it to the personal threshold they read about in the 2024 budget coverage.
TFSA Holders and the Different Conversation
Clients who hold appreciated energy or gold positions entirely inside TFSAs face none of this arithmetic. Gains inside a TFSA are not taxable regardless of size, holding period, or frequency of trading. For these clients, the relevant planning question is different: whether the current allocation still reflects their intended risk posture, and whether the war-premium gains inside the TFSA represent a concentration that warrants rebalancing on portfolio construction grounds rather than tax grounds.
This is worth raising explicitly because clients often conflate the two conversations. A client who says "I am thinking about selling my energy stocks" may mean different things depending on whether those stocks are in a TFSA, a non-registered account, or a CCPC. The account type determines the entire framework of the planning discussion.
The June 10 Calendar Anchor
The Bank of Canada's next rate decision falls on June 10, two weeks from today. If the Hormuz reopening proceeds as the MOU envisions and oil prices continue to ease, the BoC's April projection -- which assumed Brent would average $90/bbl in Q2 and decline gradually -- may prove too high. Lower oil prices reduce the energy-inflation component of CPI, which changes the BoC's calculus. A rate hold remains the overwhelming base case for June 10, but the direction of the next meaningful move shifts if the commodity picture normalizes faster than the April MPR assumed. For clients with rate-sensitive holdings, the June 10 decision is a second catalyst on the near-term calendar.