Put $200,000 into a Registered Disability Savings Plan (RDSP) over your kid's life and the Canadian government adds up to $90,000 on top: $70,000 in grants, $20,000 in bonds.

Then move to a country where she can actually get care.

The grants stop the day you become a non-resident. So do the bonds. Wind the plan down to take the money with you and the clawback rule takes three dollars of grant and bond for every dollar you pull, up to the last 10 years of both.

That is the part the checklists skip. They tell you which account to open. They go quiet on what happens to it when you leave.

Every parent of a disabled kid eventually gets handed the same checklist. Set up a special needs trust. Open the tax-advantaged disability account. Buy some life insurance to fund it. Name the trust as beneficiary. Done.

The checklist is not wrong. It is built for a family that dies in the same tax system it was born into.

Mine isn't. Maybe yours isn't either.

The real first question is jurisdictional: which country my daughter is sitting in when I die, and whether the instrument still works there. Get that order wrong and you can do everything on the checklist perfectly and still leave her exposed.

The checklist hides one thing. Every one of these structures is locked to one country, and most of them exist to protect benefits that are themselves locked to one country.

Start with the trust, because it is the piece people misunderstand most.

A third-party special needs trust (SNT) is funded with your money, never the child's. A grandparent dies, leaves everything to the trust, the trust holds it for her benefit, and when she dies whatever is left goes where you decided: her brother, a charity, back to the family. No payback to anyone.

A first party trust is funded with the child's own money. The moment something lands in her name, it is her money. In the US that means a first party trust under 42 U.S.C. 1396p(d)(4)(A), which carries a Medicaid payback clause: when she dies, the state gets reimbursed for every dollar of Medicaid it ever spent on her, off the top, before her brother sees a cent. In Ontario it means the money counts against the $40,000 asset limit that keeps her on the Ontario Disability Support Program (ODSP), unless it fits inside a $100,000 inheritance and life insurance exemption that fills up fast.

The most expensive mistake in special needs planning is smaller and dumber than picking the wrong account. It is a loving relative who writes "$50K to Alexia" in a will instead of "$50K to the trust for Alexia." Same money. One version is protected. The other breaks the plan and, in the US, hands the government a lien on the remainder.

Tell every grandparent, in writing, that nothing goes to her directly. Everything goes to the trust. That one sentence is worth more than most of the planning that comes after it.

Now the savings accounts, and the border.

In the US there is the ABLE account. As of January 1, 2026, it covers anyone whose disability began before age 46, up from 26, which just pulled millions of people into eligibility who were locked out last year. You can put in $20K a year, the first $100K doesn't count against the $2K asset limit for Supplemental Security Income (SSI), and the money grows tax-free for disability expenses. Useful. But ABLE lives inside the US benefits system, and so does the trust around it.

Because that is what an American SNT is actually for. It exists to keep her under the $2k SSI limit and on Medicaid. SSI stops once she is out of the country for 30 straight days. Medicaid is run by the states and does not travel. So all of it, the trust, the ABLE account, the careful titling, exists to protect eligibility for two programs she loses the month she moves abroad. The trust still holds the assets. The reason you contorted everything to build it is gone.

Canada has the same shape with different labels. The Henson trust is the good one: an absolute discretionary trust where the trustee has total control and your kid has no legal claim to the money, which is exactly why Ontario ignores it and lets her keep ODSP with no cap on the trust's value (ODSP Directive 4.7). It is a strong tool. Inside Ontario.

Leave Ontario and ODSP ends, because it is an Ontario program. Distribute money from a Canadian trust to a beneficiary who now lives in Mexico and you are into 25% non-resident withholding tax under Part XIII, treaty reductions aside. Move the people running the trust abroad and the trust itself can be treated as having left the country, with a tax bill for the privilege.

And then the part that comes too late to fix: Mexico and Panama do not have trusts. They are civil-law countries. The common-law trust, the thing your Ontario lawyer just drafted, is not a native legal object there. Mexico runs a bank-administered structure called a fideicomiso. Panama uses a private interest foundation. Your carefully built Henson trust may land in your new country as a foreign curiosity the local system does not quite know how to read.

One more, because this is where families lose the most money: how you fund the trust.

A broker will quote you a million dollars of 20 year term life for around $800 a year for a healthy parent in their early forties. It looks cheap. It is the wrong product. Term expires. Your kid's need does not. If the policy lapses at year 20 and she needs the money in year 35, you funded nothing.

The tool that matches the problem is permanent insurance: whole life, or a second-to-die survivorship policy that pays out when the last parent dies, which is the exact moment the trust needs cash. That runs many times the term price, somewhere between $6K and $16K a year for the same million depending on the type. The cheap quote is the easy sale. If the full permanent premium is out of reach today, buy convertible term and lock in the right to switch to permanent later without a new medical exam. Just don't confuse the cheap thing with the plan.

What I am doing with this, specifically, in the next 18 months.

I am not funding a Henson trust and maxing an RDSP just to watch both unravel at the border when we leave. The order I run is jurisdiction before instrument: decide where Alexia will actually live and get care, confirm what that country recognizes and taxes, then build the version that survives the move. I am buying convertible term now to cover the gap, because my heart is 2.5 years post-surgery and I am not leaving that exposure open while the rest gets solved. And the rule I already enforce with family: nothing in her name, ever.

The jurisdiction is the plan. A special needs trust that is airtight in Ontario and unreadable in Mérida protects nothing. It is paperwork with good intentions. Alexia is 8. If the doctors keep being wrong the way they have been since they gave her a few months, she needs this to hold for 60 more years, across at least one border, probably two. Plan for where she will be at 25, 45, 65. Not where she is now.

The mechanics of the move itself, the departure tax under Section 128.1 of the Income Tax Act, the healthcare handoff, which country actually scores out for a kid like her, that is its own essay and it is coming. This one is only about the structures. They all share one flaw, and it is the border.

One thing this week, free: take every account, trust, and policy with her name or her benefits attached to it, and ask whoever sold it to you a single question. Does this survive me leaving the country. If they don't have an answer, you just learned something more useful than the answer would have been.

There's a step underneath all of this that the jurisdiction talk skips. You don't pick the country. Your income picks it for you. A salary is paid in one place, tied to one desk, one work permit, no matter how big it is. A trust can be set up to move with you. The paycheck usually can't. And if the money that funds her care stops the day you stop showing up, you weren't mobile. You were employed somewhere expensive. The income has to become portable before any of this. Before the trust. Before the country. Building income that survives both my absence and my address is the harder problem, and it's where this series goes next.

Income first. Then the country. Then the trust.

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