How about sub modules? We atomically tag across both to keep the project in proper synchronization.
Some of these things are difficult to discuss at this point in time because we not have enough Apache knowledge and experience. What I have seen from following the release emails is the release will go through several release candidates before before a final release is made. Tagging releases as NuttX did in the past won't support that. I believe that you would have to use branches to support a series of release candidates until the release is made (and perhaps even to support further releases on the branch for bug fixes).
We can't really branch across sub-modules, can we? I think we need to know much more before we could take any clear position on this.
Greg