Kind of an old topic, but this one might be useful for someone:
As someone mentioned above - you can use a dummy form. I had to overcome this issue some time ago. At first, I totally forgot about this HTML restriction and just added the nested forms. The result was interesting - I lost my first form from the nested. Then it turned out to be some kind of a "trick" to simply add a dummy form (that will be removed from the browser) before the actual nested forms.
In my case it looks like this:
<form id="Main">
<form></form> <!--this is the dummy one-->
<input...><form id="Nested 1> ... </form>
<input...><form id="Nested 1> ... </form>
<input...><form id="Nested 1> ... </form>
<input...><form id="Nested 1> ... </form>
......
</form>
Works fine with Chrome, Firefox, and Safari. IE up to 9 (not sure about 10) and Opera does not detect parameters in the main form. The $_REQUEST global is empty, regardless of the inputs. Inner forms seem to work fine everywhere.
Haven't tested another suggestion described here - fieldset around nested forms.
EDIT: Frameset didn't work! I simply added the Main form after the others (no more nested forms) and used jQuery's "clone" to duplicate inputs in the form on button click. Added .hide() to each of the cloned inputs to keep layout unchanged and now it works like a charm.