You cannot move a sub user category or move a user category to become a sub user category. However, you can drag & drop the contents of one (sub) user category to another (sub) user category, which is easier than recreating all the values from scratch.
Steps:
1) Create a user category "foobar"
2) Drag some tags into it.
3) Create an embedded user category "mumble" in "foobar"
4) Select one of the tags in foobar.
5) Drag that tag to mumble, holding the shift key down so that it is a move.
It works if the new embedded category is in some other user category.
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