the service provider which meets the requirements of subsection (d), (B) the service recipient or the payor satisfied the applicable reporting requirements of section 6041(a), 6041A(a), or 6050W for all relevant taxable years with respect to the service provider, (C) the service recipient or the payor collected and paid over all applicable taxes imposed under subtitle C for all relevant taxable years with respect to the service provider, and (D) the service recipient or the payor demonstrates a reasonable basis for having determined that the service provider should not be treated as an employee under this section and that such determination was made in good faith. (2) 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 provider satisfied the applicable reporting requirements of sections 6012(a) and 6017 for all relevant taxable years with respect to the service recipient or payor, and (C) the service provider demonstrates a reasonable basis for determining that the service provider is not an employee under this section and that such determination was made in good faith. (3) 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. (4) Reasonable cause exception The requirements of paragraphs (1)(B) and (2)(B) shall be treated as met if the failure