In a recent Chief Counsel Advice, the factors under Revenue Ruling 57-128 were considered to determine whether the school was an instrumentality of a government. The laws in State A regulate education including public, private, and charter schools. The charter schools are funded by tax revenue, governed by boards that are independent from the local school districts, and exempt from many statutory provisions that apply to district schools. Although the charter school is publicly funded and performs a government function (providing public education), it does not do so on behalf of the State because the State exercises no meaning control over the schools day-to-day operations, and it is operated independently from the local school district. Consequently, the school does not qualify as a wholly-owned instrumentality of the state and is not eligible for the exemption from FICA tax liability under IRC Sec. 3121(b)(7)(F). CCA201519027.