I know this question is ancient and has an accepted answer, but I found a better solution to the problem. I am posting it here so I don't create a duplicate question, and the solution is still available to others.
Switch the order of the elements. Use the :before pseudo-element for the content that should be underneath, and adjust margins to compensate. The margin cleanup can be messy, but the desired z-index will be preserved.
I've tested this with IE8 and FF3.6 successfully.
