Cite as: 532 U. S. 200 (2001)
Syllabus
2007 . . . of the total wages . . . paid by [the employer] during the calendar year." Section 3121(a) establishes the annual ceiling on wages subject to Social Security tax by defining "wages" to exclude any remuneration "paid to [an] individual by [an] employer during [a] calendar year" that exceeds "remuneration . . . equal to the contribution and benefit base . . . paid to [such] individual . . . during the calendar year with respect to which such contribution and benefit base is effective." Section 3306(b)(1) similarly limits annual wages subject to FUTA tax. Pp. 208-209.
(b) The Government calls attention to these provisions' constant references to wages paid during a calendar year as the touchstone for determining the applicable tax rate and wage base. The meaning of this language, the Government contends, is plain: Wages are taxed according to the calendar year they are in fact paid, regardless of when they should have been paid. The Court agrees with the Company that Social Security Bd. v. Nierotko, 327 U. S. 358, undermines the Govern-ment's plain language argument. The Nierotko Court concluded that, for purposes of determining a wrongfully discharged worker's eligibility for Social Security benefits under § 209(g), as that provision was formulated in the 1939 Amendments to the Social Security Act, a backpay award had to be allocated as wages to calendar quarters of the year "when the regular wages were not paid as usual." Id., at 370, and n. 25. The Court found no conflict between this allocation-back rule and language in § 209(g) tying benefits eligibility to the number of calendar quarters "in which" a minimum amount of "wages" "has been paid." Nierotko's allocation holding for benefits eligibility purposes, which the Government does not here urge the Court to overrule, thus turned on an implicit construction of § 209(g)'s terms—"wages" "paid" "in" "a calendar quarter"—to include "regular wages" that should have been paid but "were not paid as usual," id., at 370. Given this construction, it cannot be said that the FICA and FUTA provisions prescribing tax rates based on wages paid during a calendar year have a plain meaning that precludes allocation of backpay to the year it should have been paid. Pp. 209-212.
(c) However, the Court rejects the Company's contention that, because Nierotko read the 1939 "wages paid" language for benefits eligibility purposes to accommodate an allocation-back rule for backpay, the identical 1939 "wages paid" language for tax purposes must be read the same way. Nierotko dealt specifically and only with Social Security benefits eligibility, not with taxation. The Court's allocation holding in Nierotko in all likelihood reflected concern that the benefits scheme created in 1939 would be disserved by allowing an employer's wrong-
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