OPINION OF THE COURT
ROSENN, Circuit Judge.
This appeal presents the narrow but difficult question of whether taxpayers are exempt from Federal Insurance Contributions Act (FICA) taxation on amounts paid prior to January 1,1984, pursuant to salary reduction agreements, for the purchase of retirement annuities qualifying for income tax deferral. The issue arises in connection with a refund suit instituted by the taxpayer, Temple University, to recover $690,584.07 in FICA taxes paid during the taxable years 1979 through 1982, inclusive, on monies which its employees had agreed to apply to the purchase of retirement annuities qualifying for income tax deferral under 26 U.S.C. § 403(b). The district court, finding neither statutory nor judicial [128]*128support for plaintiffs position, held that plaintiff was not entitled to a refund, 595 F.Supp. 94. We affirm.
I.
The facts of this case are not in dispute. The plaintiff is an institution of higher education and part of the Commonwealth System of Higher Education of Pennsylvania. It is organized and operated as a nonprofit corporation and is exempt from federal income tax under section 501(a) and section 501(c)(3) of the Internal Revenue Code. 26 U.S.C. §§ 501(a), (c)(3). ' As an organization described in section 501(c)(3), the plaintiff established an annuity plan for its employees under section 403(b) of the Code.1 26 U.S.C. § 403(b). The plan operated throughout the taxable years involved in this case. Under the plaintiffs plan, employees desiring to purchase nonforfeitable, nontransferable retirement annuity contracts agreed to accept a salary reduction amounting to a specified percentage of their compensation. These deductions were then applied, along with supplemental contributions from the employer, to the purchase of the retirement annuities. An employee could execute only one such agreement in any year. Each agreement, legally binding and irrevocable, applied only to compensation earned after its effective date and during its term.
During the taxable years involved in this case, 1979 through 1982, inclusive, the plaintiff included the deductions from its employees’ pay under these salary reduction agreements in computing the amount of their “wages” for purposes of the payroll tax under FICA. Plaintiff paid the FICA taxes on the amounts so withheld. This construction of the withholding requirement conformed to Rev.Rul. 65-208, 1965-2 C.B. 383, which required the inclusion of amounts withheld pursuant to a salary reduction agreement in the employee’s taxable wage base for purposes of the FICA tax, even though the amounts so withheld were excluded from the employee’s federal taxable income pursuant to section 403(b) of the Code.
On June 8, 1981, the Supreme Court decided Rowan Companies v. United States, 452 U.S. 247, 101 S.Ct. 2288, 68 L.Ed.2d 814 (1981). In Rowan, the Court held that “wages” must be consistently interpreted for income tax withholding and FICA purposes. Id. at 263, 101 S.Ct. at 2297. Subsequent to the Rowan decision, the plaintiff filed timely claims for refund of the employer taxes it paid based on the salary reduction amounts held includable in the FICA wage base under Rev.Rul. 65-208. The plaintiff also sought a refund of the taxes paid in behalf of its employees and withheld from their wages. The Commissioner rejected completely the plaintiff’s claims for refund and the plaintiff thereupon timely filed this suit. Both parties moved for summary judgment.
The district court granted the Government’s motion for summary judgment. The court held that Rev.Rul. 65-208 correctly construed the relevant statutory provisions and that it comported with congressional policies against permitting individuals to control the portion of their compensation which was to be included in the Social Security FICA wage base. It rejected the plaintiff’s contention that the decision of the Supreme Court in Rowan required that the salary reduction amounts involved in this case be treated consistently for income tax and FICA purposes. The court concluded that such salary reductions were not excluded from the FICA wage base merely because they were excluded from taxable [129]*129income for income tax purposes under section 403(b), noting that in subsequent legislation Congress had codified the rule embodied in Rev.Rul. 65-208. “Congress,” stated the district court, “[has] specifically rejected the language in Rowan.” From this adverse judgment, Temple University appeals.
II.
The inclusion of salary reductions, made for the purchase of retirement annuities, in the taxable wage base for purposes of levying FICA taxes presents a question of law that is fully reviewable on appeal. Cf. Struble v. New Jersey Brewery Employees’ Welfare Trust Fund, 732 F.2d 325, 330 (3d Cir.1984) (“Our review of the district court’s grant of summary judgment is plenary.”).
Plaintiff relies on two independent and distinct grounds in support of its position that the salary reductions contributed by plaintiff for the purchase of retirement annuities for its employees were not subject to FICA tax. Its principal reason is that during the years at issue, section 3121(a)(2) of the Code statutorily exempted such salary reductions from tax. The alternative basis is that the Supreme Court’s 1981 decision in Rowan requires, in the absence of express congressional intent to the contrary, that both the income tax and FICA tax provisions be similarly interpreted. We consider each of these grounds in turn.
A.
Section 3121(a) of the Code, 26 U.S.C. § 3121(a), defines “wages” subject to FICA taxes. This section, as applicable to amounts paid prior to January 1, 1984, excluded from the definition of “wages”:
the amount of any payment (including any amount paid by an employer for insurance or ammuities, or into a fund, to provide for any such payment) made to, or on behalf of, an employee or any of his dependents under a plan or system established by an employer which makes provision for his employees generally ... on account of—
(A) retirement____
26 U.S.C. § 3121(a)(2). Plaintiff argues that this exclusion covers both the salary reductions and the salary supplements. The Government, on the other hand, takes the position that only the salary “supplements” are excluded, and this case involves a salary reduction agreement.
The Government’s position is directly supported by Rev.Rul. 65-208, 1965-2 C.B. 383, and its consistent application since its adoption in 1965. In this revenue ruling, the Internal Revenue Service has taken the position that amounts withheld pursuant to a salary reduction agreement are includable in the employee’s taxable wage base for FICA tax purposes, even though the sums so withheld are excluded from the employee’s federal taxable income pursuant to section 403(b) of the Code. That Congress saw Rev.Rul. 65-208 as the properly applicable law during the period in question is suggested by statements made in the legislative history of the Social Security Amendments of 1983 (the “1983 Act”), Pub.L. No. 98-21, 97 Stat. 65. In relevant part, this Act explicitly incorporated Rev.Rul. 65-208 into the Code.2 Congress, in amending the law in this manner, saw itself merely codifying the prior law as articulated in Rev. Rui. 65-208. This is seen in the Senate committee report:
The bill also provides that any amounts paid by an employer to a tax-sheltered annuity by reason of a salary reduction agreement between the employer and the employee would be includible in the employee’s social security wage base. The committee intended that the provision would merely codify the holding of Revenue Ruling 65-208, 1965-2 Cum.Bull. 383....
S.Rep. No. 23, 98th Cong., 1st Sess. 41, reprinted in 1983 U.S.Code Cong. & Ad. News 143, 182 (emphasis added).
[130]*130Moreover, the legislative history of the 1983 Act also reflects the long-standing congressional intent to restrict the forms of compensation excluded from the FICA wage base. As stated in the Senate report;
Under cash or deferred arrangements, certain tax-sheltered annuities, certain cafeteria plans, and eligible State deferred compensation plans, the employer contributes funds which are set aside by individual employees for individual savings arrangements, and thus, the committee believes that such employer contributions should be included in the FICA base, as is the case for IRA contributions. Otherwise, individuals could, in effect, control which portion of their compensation was to be included in the social security wage base. This would make the system partially elective and would undermine the FICA tax base.
Id. at 40, 1983 U.S.Code Cong. & Ad.News 181. This report further supports the position that Congress, in the 1983 Act, was merely attempting to codify the preRowan law, embodied in Rev.Rul. 65-208.
Common sense also supports the preRowan applicability of Rev.Rul. 65-208, and the resulting conclusion that section 3121(a) of the Code applied only to the salary supplements. FICA taxes fund a national system of social insurance that supports important and extensive social security and medicare health programs. The purpose and use of FICA funds, then, differ markedly from the objectives underlying the federal income tax system. As stated by the Senate:
The social security program aims to replace the income of beneficiaries when that income is reduced on account of retirement and disability. Thus, the amount of “wages” is the measure used both to define income which should be replaced and to compute FICA tax liability. Since the security system has objectives which are significantly different from the objective underlying the income tax withholding rules, the committee believes that amounts exempt from income tax withholding should not be exempt from FICA unless Congress provides an explicit FICA tax exclusion.
Id. at 42, U.S.Code Cong. & Ad.News 1983, 183. Congress has provided no explicit FICA tax exclusion for the salary reduction amounts at issue here. Thus, there is ample justification for Rev.Rul. 65-208’s differing treatment of such deductions for purposes of FICA on the one hand and federal income tax on the other.
The plaintiff presents several grounds, independent of Rowan, for challenging the rule established in Rev.Rul. 65-208. For example, the plaintiff relies on Treas.Reg. § 31.3121(a)(2)-l(d) which provides:
It is immaterial for purposes of this exclusion [from FICA tax of contributions made by an employer on behalf of an employee pursuant to a retirement plan] whether the amount or possibility of such benefit payments is taken into consideration in fixing the amount of an employee’s remuneration or whether such payments are required, expressly or impliedly, by the contract of service.
The Government counters by arguing that this regulation reflects not an explicit salary reduction agreement, but rather, the treatment of employee retirement benefits in a collective bargaining agreement. Benefits paid by employers under collective bargaining agreements are not treated as paid under salary reduction agreements within the meaning of Rev.Rul. 65-208. Hence, they are not regarded as part of the taxable wage base of the employees for FICA purposes. The plaintiff also relies on Rev.Rul. 181, 1953-2 C.B. 111. This revenue ruling, however, was specifically distinguished in Rev.Rul. 65-208 on the ground that the employer made the contribution involved from its own funds and not under a salary reduction plan.
Even if the foregoing analysis were rejected, and section 3121(a) is seen as applicable to salary reductions, the result is the same. This is due to the amendments found in the 1983 Act — amendments that, in the event the plaintiff’s position regarding section 3121(a) has merit, should be seen as having retroactive application. The [131]*1311983 Act contained numerous provisions concerning FICA coverage and taxation. Some of the amendments were enacted in reaction to the Supreme Court’s Rowan decision. Congress, in section 327(b)(1) of the 1983 Act, Pub.L. No. 98-21, § 327(b)(1), 97 Stat. 65, 127, sought to extricate the Treasury from the requirement that the definition of “wages” or FICA purposes be interpreted in the same manner as the definition of “wages” for income tax withholding purposes. The “decoupling” provision of the 1983 Act reads as follows:
Nothing in the regulations prescribed for purposes of chapter 24 (relating to income tax withholding) which provides an exclusion from “wages” as used in such chapter shall be construed to require a similar exclusion from “wages” in the regulations prescribed for purposes of this chapter.
Section 327(b)(1) of the 1983 Act (codification is found following § 3121(a)(20) of the Code).
The 1983 Act also amended the section 3121 definition of “wages” for FICA purposes in a number of very specific respects. First, Congress amended section 3121(a)(2) by striking “(A) retirement” plans from the list of exclusions under that provision. See section 324(a)(3)(A) of the 1983 Act. Second, Congress also struck section 3121(a)(3), relating to the exclusion for non-plan retirement arrangements. See id. at section 324(a)(3)(B). Congress then added a new section, 3121(a)(5)(E), which provides that the FICA wage base excludes:
any payment made to, or on behalf of, an employee or his beneficiary ... under or to an annuity contract described in section 403(b), other than a payment for the purchase of such contract which is made by reason of a salary reduction agreement (whether evidenced by a written instrument or otherwise).
Id. at section 324(a)(2)(C) of the 1983 Act (emphasis added) (now codified at 26 U.S.C. § 3121(a)(5)(D)).
The specific amendments concerning section 3121 effectively codify Rev.Rul. 65-208. If applicable, these alterations defeat plaintiff’s statutory argument. The 1983 Act, however, stated that these amendments to section 3121 (as well as the Rowan decoupling provision) were to be effective only for remuneration paid after December 31, 1983. See sections 324(d)(1) & 327(d)(1) of the 1983 Act. Thus, by applying the amendments prospectively, the 1983 Act does not, by itself, affect the years involved in this suit.3
■In 1984, however, Congress addressed the question of retroactivity. Specifically, section 2662(g) of the Deficit Reduction Act of 1984 (the “1984 Act”), Pub.L. No. 98-369, § 2662(g) 98 Stat. 494, 1160, amends the 1983 Act by changing the effective date of the Rowan decoupling provision as follows:
Section 327(d) of such amendments ... is amended to read as follows:
:}: * * :{: * ¡k
“(2) The amendments made by subsection (b) and subsection (c)(4) shall apply to remuneration ... paid after March 4, 1983, and to any such remuneration paid on or before such date which the employer treated as wages when paid.’’
Id. (emphasis added). By making the change retroactive, there can be no doubt [132]*132that Congress intended to cut off all claims to refunds based on the rationale of Rowan, i.e., that “wages” for FICA purposes are presumptively the same as “wages” for income tax withholding purposes.
Plaintiff, however, considers significant Congress’ failure also to explicitly make the specific amendments to section 3121, which effectively codify Rev.Rul. 65-208, retroactive. “It is ... clear,” argues the plaintiff, “that Congress did not retroactively extinguish the right to refund based on section 3121(a)(2).” However, the following statement in the legislative history of the 1984 Act demonstrates that Congress clearly intended to bar the type of refund sought by the plaintiff here:
The provision in the [Social Security] Amendments applies to remuneration paid after December 31, 1983, for FICA and social security benefit purposes and to remuneration paid after December 31, 1984, for FUTA (Federal Unemployment Tax Act) purposes. Thus, it is possible that this provision could be cited as demonstrating congressional intent that the reasoning of the Rowan decision should generally apply before these dates to types of remuneration other than meals and lodging excluded under section 119, e.g., to contributions under a salary reduction agreement to tax-sheltered annuities (sec. 403(b)). These contributions have been held by the Treasury Department to be taxable for FICA purposes (Revenue Ruling 65-208) even though they are exempt by regulation from income tax withholding. If the 1965 revenue ruling were determined to be invalid, then employers and employees would be eligible for tax refunds for open years because taxable wages would be lower. In addition, wages for benefit computation purposes would be reduced, leading in some cases to reduction of social security benefits being paid to current beneficiaries and recoupment of a portion of benefits which have been paid in recent years on the basis of wage records which included the salary reduction contributions.
Explanation of Provision
In order to avoid the inferences which this provision could raise, the bill clarifies the effective date of the provision overriding the Rowan decision so that the provision applies for all purposes, other than the treatment of certain employer-provided meals and lodging, both to remuneration paid after March 4, 1983, and to remuneration paid on or before March 4, 1983, which the employer treated as wages when paid. For example, if an employer treated as wages, for FICA or FUTA taxes (or both), the amounts contributed during 1982 to an employee’s tax-sheltered annuity pursuant to a salary reduction agreement, the FICA or FUTA taxes (as the case may be) paid by the employer and employee may not be refunded or credited. The committee intends no inference as to the treatment of amounts paid on or before March 4, 1983, which the employer did not treat as wages when paid.
H.R.Rep. No. 432, 98th Cong., 1st Sess. 1658, reprinted in 1984 U.S.Code Cong. & Ad.News 697, 1280-81 (footnote omitted).
Faced with this clear congressional purpose to ban refunds in this type of case, the question becomes whether this intent can be implemented, assuming this is necessary, see supra note 3, despite Congress’ failure explicitly to provide for retroactivity. Plaintiff stresses the actual failure of Congress, through inadvertence or otherwise, to make the specific section 3121 amendments retroactive and argues that the changes should, on the basis of this failure, not be seen as applying to this case. In support of its position, plaintiff cites Iselin v. United States, 270 U.S. 245, 46 S.Ct. 248, 70 L.Ed. 566 (1926). In Iselin, the Supreme Court, through Justice Brandéis, stated that “[w]hat the Government asks is not a construction of a statute, but, in effect, an enlargement of it by the court, so that what was omitted, presumably by inadvertence, may be included within its scope. To supply omissions transcends the [133]*133judicial function.” Id. at 251, 46 S.Ct. at 250.
It is generally true that courts should look to the plain language of, and not rewrite, statutes. See, e.g., id,.; Tracy Leigh Development Corp. v. Government of the Virgin Islands, 501 F.2d 439, 442 (3d Cir.1974) (relying on Frankfurter, Some Reflections on the Reading of Statutes, 47 Colum.L.Rev. 527 (1947)). However, the Supreme Court recently stated as follows:
We begin with the familiar canon of statutory construction that the starting point for interpreting a statute is the language of the statute itself. Absent a clearly expressed legislative intention to the contrary, that language must ordinarily be regarded as conclusive.
Consumer Product Safety Commission v. GTE Sylvania, 447 U.S. 102, 108, 100 S.Ct. 2051, 2056, 64 L.Ed.2d 766 (1980) (emphasis added). In the Iselin case cited by plaintiff, there was no “clearly expressed legislative intention.” In the instant case, however, Congress’ intent, as expressed in the legislative history, see supra, is very clear. Congress intended, through the 1984 amendments, to eliminate the very type of refund sought in the instant case. Thus, in light of the recent guidance from the Supreme Court, the statute should be construed so as to reach this result. Furthermore, “[i]t is a well settled rule that statutory exemptions from taxation, being a matter of grace, are to be strictly and narrowly construed.” King Christian Enterprises, Inc. v. Government of the Virgin Islands, 345 F.2d 633, 637 (3d Cir. 1965), quoted in Tracy Leigh Development Corp. v. Government of the Virgin Islands, 501 F.2d at 443. We therefore do not see section 3121(a) as supporting plaintiff’s claim for a refund.
B.
In the alternative, plaintiff relies on the Rowan decision. The instant case involves payments made to establish a retirement annuity plan of the type described in section 403(b) of the Code. Pursuant to section 403(b), the entire amount contributed, i.e., both the salary reduction and the salary supplement amounts, is excludable from the employee’s gross income for federal income tax purposes. However, Rev.Rul. 65-208, which the plaintiff itself followed over a period of years, requires that the salary reduction sums be included for FICA purposes. Because of this variance in treatment for income tax and FICA purposes, the Rowan case is significant.
In Rowan Companies, Inc. v. United States, 452 U.S. 247, 101 S.Ct. 2288, 68 L.Ed.2d 814 (1981), the Supreme Court considered whether meals and lodging provided employees by their employer on its business premises for its own convenience constituted “wages” for purposes of FICA and the FUTA. Treasury regulations of long standing specifically excluded meals and lodging from the definition of “wages” for income tax withholding purposes but included them within the definition of “wages” for FICA and FUTA purposes. The district court and the court of appeals had found that the different interpretations of the definition of “wages” were justified by the different purposes of FICA and FUTA, on the one hand, and income tax withholding, on the other.
The Supreme Court reversed, holding that, absent express congressional intent to the contrary, the term “wages” is to be interpreted in the same manner for FICA and FUTA purposes as for income tax withholding purposes. The Court stated:
The plain language and legislative histories of the relevant Acts indicate that Congress intended its definition to be interpreted in the same manner for FICA and FUTA as for income tax withholding.
Id. at 263, 101 S.Ct. at 2297.
If it has vitality, Rowan obviously helps the plaintiff here. As noted earlier, however, Congress, in the 1983 Act, expressly overruled the broad holding of Rowan, at least as it applied to claims for refund of FICA taxes on salary reductions. In the 1984 Act, Congress gave retroactive effect to the 1983 legislation. Thus, for the plaintiff to rely on its alternative argu[134]*134ment, it must show that Congress acted unconstitutionally in overruling Rowan. To this end, plaintiff presents two principal arguments.4
First, plaintiff alleges that Congress violated the equal protection clause by impermissibly distinguishing among employers. In particular, it asserts that Congress, in denying refunds, improperly favored employers who had failed to comply with Rev. Rui. 65-208 (and thus failed to pay the tax) over those who had complied with the ruling. This argument is without merit. The legislative history of the 1984 Act expressly disclaims any intent to validate failures to withhold FICA taxes. See H.R.Rep. No. 432, supra, at 1658. Thus, the Government, if not barred by the statute of limitations, conceivably could sue the non-complying employers and recover from them the additional taxes due.
A more troublesome argument is that Congress, in imposing a retroactive tax, violated the Due Process Clause. It is clear that Congress may, without violating the due process clause, enact legislation having retroactive application if it is justified by a rational legislative purpose. Pension Benefit Guaranty Corp. v. R.A. Gray & Co., — U.S.-, 104 S.Ct. 2709, 2718, 81 L.Ed.2d 601 (1984). Furthermore, when such legislation is “curative”5 in character, as in this instance, the retroactive application is typically entitled to be liberally construed. See Goddard v. Frazier, 156 F.2d 938, 942 (10th Cir.1946); 2A C. Sands, Sutherland Statutory Construction § 41.-11, at 290 (4th ed. 1973). There also appears to be a greater tolerance toward retroactive application of laws which coincide with longstanding public policy than where that is not the case. United States v. Perry, 431 F.2d 1020, 1024 (9th Cir.1970).
Almost without exception, Congress has given general revenue statutes an effective date prior to the date of actual enactment, as it has to the Internal Revenue Codes of 1939 and 1954. United States v. Darusmont, 449 U.S. 292, 296, 101 S.Ct. 549, 551, 66 L.Ed.2d 513 (1981). With respect to income tax statutes, retroactive application apparently has been confined to short periods so as to include profits from transactions while the statute was in process, or within so much of the calendar year as preceded the enactment. United States v. Hudson, 299 U.S. 498, 500-501, 57 S.Ct. 309, 310, 81 L.Ed. 370 (1937), cited with approval in United States v. Darusmont, 449 U.S. at 297, 101 S.Ct. at 552. Taxation is “but a way of apportioning the cost of government among those ... privileged to enjoy its benefits and [who] must bear its burdens” and its “retroactive imposition does not necessarily infringe due process.” Welch v. Henry, 305 U.S. 134, 146-47, 59 S.Ct. 121, 125-26, 83 L.Ed. 87 (1938).
It is true that Welch v. Henry created some doubt as to the constitutional validity of imposing retroactive tax liability for periods preceding the year prior to the passage of the legislation. 305 U.S. at 146-51, 59 S.Ct. at 125-28. In fact, some state courts, in applying Welch v. Henry, have held unconstitutional any tax statute which attempts to be applied retroactively beyond the year of the legislative session immediately preceding the year of the statute’s enactment. See, e.g., Commonwealth v. Budd Co., 379 Pa. 159, 108 A.2d 563 (1954), appeal dismissed, 349 U.S. 935, 75 S.Ct. 782, 99 L.Ed. 1264 (1955); Gulf & Western Corp. v. Commonwealth, 74 Pa. Commw. 493, 459 A.2d 1369 (1983). The [135]*135Supreme Court, however, has never actually prohibited such retroactivity. Instead, the Court has spoken only in vague terms, permitting an income tax statute to be retroactively applied to “recent transactions.” Welch v. Henry, 305 U.S. at 150, 59 S.Ct. at 127; Cooper v. United States, 280 U.S. 409, 411, 50 S.Ct. 164, 165, 74 L.Ed. 516 (1930); cf. United States v. Hudson, 299 U.S. at 500, 57 S.Ct. at 310 (“relatively short periods”). Similarly, no federal court of appeals has yet adopted an absolute temporal limitation on retroactivity.6 See, e.g., Shanahan v. United States, 447 F.2d 1082, 1084 (10th Cir.1971); First National Bank v. United States, 420 F.2d 725, 730, 190 Ct.Cl. 400, cert. denied, 398 U.S. 950, 90 S.Ct. 1868, 26 L.Ed.2d 289 (1970); Wilgard Realty Co. v. Commissioner, 127 F.2d 514, 517 (2d Cir.1942).
We find some guidance in the rather flexible criteria delineated by the Court in Welch v. Henry: “In each case it is necessary to consider the nature of the tax and the circumstances in which it is laid before it can be said that its retroactive application is so harsh and oppressive as to transgress the constitutional limitation.” 305 U.S. at 147, 59 S.Ct. at 126. The federal courts have generally interpreted these criteria as indicating that “[rjetroactive operation is constitutional where it is not harsh, arbitrary or unfair.” Shanahan, 447 F.2d at 1084. An amplification of this principle is provided by an earlier case:
The decisive test in this instance is whether this taxpayer has had its expectations as to taxation unreasonably disappointed____ [Rjetroactive taxation is not so arbitrary and oppressive as to be unconstitutional if it is no more burdensome than the taxpayer should have expected it to be when he did the thing which created the tax liability____ And when it is not, whether the period of retroactivity is comparatively long or short is of little consequence provided it isn’t too long to be within reason.
Wilgard Realty Co., 127 F.2d at 517.
In the instant case, Congress believed that the broad holding of Rowan contravened the policies and principles underlying the statutory schema and philosophy of our social security and Medicare systems. It therefore overruled that holding and codified Rev.Rul. 65-208 — a ruling that had been applied and enforced for over fifteen years. Even this plaintiff had conformed to it in making its reports and paying its FICA taxes quarter-annually year after year, including for a significant period after the Rowan decision. Thus, it can hardly be said that the plaintiff had its tax expectations unreasonably disappointed or that it is a victim of oppressive taxation as a result of the legislation overruling Rowan. The 1984 Act, as demonstrated by its legislative history, merely averts the potentially disruptive effect of the Rowan decision on the multitude of transactions properly reported by taxpayers in accordance with the applicable rule of law at the time. See H.R.Rep. No. 432, supra, at 1658. The statute imposes neither a new nor an unforeseeable or unexpected tax liability on either the employer or its employees. Thus, we believe that retroactive application of the statute under the circumstances we have here “is not so arbitrary and oppressive as to be unconstitutional.” Id. We therefore reject plaintiff’s alternative argument based on Rowan.
IV.
In summary, we hold that neither 26 U.S.C. § 3121(a), even as it existed prior to the relevant amendments, nor the Rowan [136]*136decision entitles plaintiff to a refund of the FICA taxes paid. Accordingly, the judgment of the district court will be affirmed.