had a reasonable basis not to treat an individual as an employee for purposes of this section, subparagraph (A) shall only apply for purposes of determining whether the taxpayer meets the requirements of subparagraph (A), (B), or (C) of subsection (a)(2). (3) Effect of reclassification on service providers A determination by the Secretary that a service provider should have been treated as an employee shall be effective with respect to the service provider no earlier than the notice date if— (A) the service provider entered into a written contract with the service recipient or payor which meets the requirements of subsection (d), (B) the service recipient or payor satisfied the applicable reporting requirements of sections 6012(a) and 6017 for all relevant taxable years with respect to the service provider, or (C) the service recipient demonstrates a basis for determining that the service provider is not an employee under this section and that such determination was made in good faith. (4) Notice date For purposes of this subsection, the term notice date means the 30th day after the earliest of— (A) the date on which the first letter of proposed deficiency which allows the service provider, the service recipient, or the payor an opportunity for administrative review in the Internal Revenue Service Office of Appeals is sent, (B) the date on which a deficiency notice under section 6212 is sent, or (C) the date on which a notice of determination under section 7436(b)(2) is sent. (5) No restriction on administrative or judicial review Nothing in this subsection shall be construed as limiting any provision of law which provides an opportunity for administrative or judicial review of a determination by the Secretary. (h) Definitions For purposes of this section— (1) Service provider (A) In general The term service provider means any qualified person who performs service for another qualified person. (B) Qualified person The term qualified person means— (i) any natural person, or (ii) any entity. (2) Service recipient