214
Opinion of the Court
The 1939 Amendments adopting the "wages paid" rule for taxation reflected Congress' worry that, as tax rates increase from year to year, "difficulties and confusion" would attend the taxation of wages payable in one year, but not actually paid until another year. S. Rep. No. 734, 76th Cong., 1st Sess., 75-76; see also H. R. Rep. No. 728, 76th Cong., 1st Sess., 57-58. Congress understood that an employee's annual compensation may be "based on a percentage of profits, or on future royalties, the amount of which cannot be determined until long after the close of the year." S. Rep. No. 734, 76th Cong., 1st Sess., at 75. Requiring employers to "estimate unascertained amounts and pay taxes and contributions on that basis" would "cause a burden on employers and administrative authorities alike." Id., at 75- 76. Congress correctly anticipated that "[t]he placing of [FICA and FUTA] tax[es] on the 'wages paid' basis [would] relieve this situation." Id., at 76. "Under the amendment the rate applicable would be the rate in effect at the time that the wages are paid and received without reference to the rate which was in effect at the time the services were performed." H. R. Rep. No. 728, supra, at 58.
As an additional ground for construing the tax and benefits provisions in pari materia, the Company insists that Congress incorporated Nierotko's treatment of backpay into the tax provisions when it amended the Social Security Act shortly after Nierotko was decided. Prior to 1946, the FICA and FUTA wage bases had been defined in terms of remuneration "paid . . . with respect to employment during" a given year. 1935 Act, § 811(a), 49 Stat. 639 (FICA); 1939 Amendments, § 606, 53 Stat. 1383 (FUTA). Paralleling the 1939 Amendments to the tax rate provisions, Congress in 1946 established the current "wages paid" rule for identifying the wages that compose the FICA and FUTA wage bases in a given year. Social Security Act Amendments of 1946 (1946 Amendments), §§ 412, 414, 60 Stat. 989-991 (codified at 26 U. S. C. §§ 3121(a), 3306(b)(1)). The 1946 law amended
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