If you die during the term of the QPRT, the residence would be included in your estate at its full fair market value at the time of year death. Although the asset protection benefits would have been realized, the tax and economic benefits of the QPRT would be lost. However, you would be no worse off than if you had not created the QPRT, other than transactional costs in establishing the QPRT. Also, the gift tax credits used initially or any gift taxes actually paid would be restored for use in transferring your estate to your heirs.