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FSA Dependent Care Excess Contribution Taxable for SIT Only (No FIT, SS, Medicare)

Hello Benefits/Payroll Experts,

We are currently evaluating a requirement after transitioning to the US Oracle Payroll Tax Engine (USOPTE) and would appreciate guidance on the Oracle-recommended approach.

Business Requirement: We have a Dependent Care FSA (DCFSA) pretax deduction element with the following Wisconsin-specific tax treatment:

  1. Employee contributions up to $5,000 remain pretax.
  2. Contributions exceeding $5,000 must be subject to Wisconsin State Income Tax (SIT). The excess amount should remain exempt from: Federal Income Tax (FIT), Social Security and Medicare.

Approaches Evaluated: I have explored a few options but have not yet been able to achieve the exact desired behavior.

Approach 1: Two Pretax Deduction Elements. Element A limited to $5,000. Element B created to capture the excess amount above $5,000. Both elements were configured as pretax deductions. I adjusted the component group rules for Element B; however, there was no tax impact, which appears to be expected since the system treats the pretax deduction classification as exempt from taxation.

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