"According to the IRS, a rehire due to COVID-19-related 'unforeseen circumstances' generally would not disqualify an individual's prior retirement from being considered a bona fide retirement under a defined benefit plan. However, the IRS cautioned that such a rehire cannot include any prearrangement to rehire the individual prior to the individual's retirement. Such a prearrangement still yields a retirement that is not 'bona fide.' "