Client is in desparate need of funds for health issues. Has MP and PS plans but has been an S-Corp and can't borrow. Can he elect c-corp status and qualify for loan or is account balance S-corp "tainted"? Any other suggestions on how he can get funds? Can't terminate, collective bargained employees are also covered.

While I am not an expert regarding the S-Corp rules, I would see if it is possible to allow in-service or hardship withdrawals from the plan(s).

The former S corp contributions and related earnings are not tainted, according to recent informal advice from authoritative IRS officals. We cannot find any formal authority one way or another. But a conversion seems very drastic, so check out other possibilities.