Cite as: 532 U. S. 200 (2001)
Opinion of the Court
Both sides in this controversy have offered plausible interpretations of Congress' design. We set out next the parties' positions and explain why we ultimately defer to the Internal Revenue Service's reasonable, consistent, and longstanding interpretation of the FICA and FUTA provisions in point. Under that interpretation, wages must be taxed according to the year they are actually paid.
A
In the Government's view, the text of the controlling FICA and FUTA tax provisions explicitly instructs that employment taxes shall be computed by applying the tax rate and wage base in effect when wages are actually paid. In particular, the Government calls attention to the statute's constant references to wages paid during a calendar year as the touchstone for determining the applicable tax rate and wage base. 26 U. S. C. § 3111(a) (setting Social Security tax rates for "wages paid during" particular calendar years); § 3121(a) (defining Social Security wage base in terms of "remuneration . . . paid . . . during the calendar year"); § 3301 (setting FUTA tax rate as a percentage of "wages . . . paid . . . during the calendar year"); § 3306(b)(1) (defining FUTA wage base in terms of "remuneration . . . paid . . . during any calendar year"). 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.
In support of this reading, the Government observes that Congress chose the words in the current statute specifically to replace language in the original 1935 Social Security Act providing that FICA and FUTA tax rates applied to wages paid or received "with respect to employment during the calendar year." Social Security Act (1935 Act), §§ 801, 804, 901, 49 Stat. 636-637, 639 (emphasis added). The Treasury Department had interpreted this 1935 language to mean that wages are taxed at "the rate in effect at the time of the
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