by owner This section shall not apply with respect to any service provided by a service provider to a service recipient if the service provider owns any interest in the service recipient or any payor with respect to the service provided. The preceding sentence shall not apply in the case of a service recipient the stock of which is regularly traded on an established securities market. (g) Limitation on reclassification by secretary For purposes of this title— (1) Effect of reclassification on service recipients and payors A determination by the Secretary that a service recipient or a payor should have treated a service provider as an employee shall be effective with respect to the service recipient or payor no earlier than the notice date if— (A) the service recipient or the payor entered into a written contract with the service provider which meets the requirements of subsection (d), (B) the service recipient or the payor satisfied the applicable reporting requirements of section (a) or 6041A(a) for all relevant taxable years with respect to the service provider, and (C) 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) Burden of proof (A) In general If— (i) a taxpayer establishes a prima facie case that it was reasonable not to treat an individual as an employee for purposes of this section, and (ii) the taxpayer has fully cooperated with reasonable requests from the Secretary of the Treasury or his delegate, then the burden of proof with respect to such treatment shall be on the Secretary. (B) Exception for other reasonable basis In the case of any issue involving whether the taxpayer 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).