Cite as: 532 U. S. 200 (2001)
Opinion of the Court
stead, we defer to the Commissioner's regulations as long as they "implement the congressional mandate in some reasonable manner." Id., at 307. "We do this because Congress has delegated to the [Commissioner], not to the courts, the task of prescribing all needful rules and regulations for the enforcement of the Internal Revenue Code." National Muffler Dealers Assn., Inc. v. United States, 440 U. S. 472, 477 (1979) (citing Correll, 389 U. S., at 307 (citing 26 U. S. C. § 7805(a))). This delegation "helps guarantee that the rules will be written by 'masters of the subject' . . . who will be responsible for putting the rules into effect." 440 U. S., at 477 (quoting United States v. Moore, 95 U. S. 760, 763 (1878)).
The Internal Revenue Service has long maintained regulations interpreting the FICA and FUTA tax provisions. In their current form, the regulations specify that the employer tax "attaches at the time that the wages are paid by the employer," 26 CFR § 31.3111-3 (2000) (emphasis added), and "is computed by applying to the wages paid by the employer the rate in effect at the time such wages are paid," § 31.3111-2(c) (emphasis added); see §§ 31.3301-2, -3(b) (same for FUTA). Echoing the language in 26 U. S. C. § 3111(a) (FICA tax) and § 3301 (FUTA tax), these regulations have continued unchanged in their basic substance since 1940. See T. D. 6516, 25 Fed. Reg. 13032 (1960); Treas. Regs. 107 (as amended by T. D. 5566, 1947-2 Cum. Bull. 148); Treas. Regs. 106 (as amended by T. D. 5566, 1947-2 Cum. Bull. 148); Treas. Regs. 106, §§ 402.301-.303, 402.401- .403 (1940). Cf. National Muffler, 440 U. S., at 477 ("A regulation may have particular force if it is a substantially contemporaneous construction of the statute by those presumed to have been aware of congressional intent.").
Although the regulations, like the statute, do not specifically address backpay, the Internal Revenue Service has consistently interpreted them to require taxation of back wages according to the year the wages are actually paid,
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