Can we create two forums with the same users but different user permissions?

You can. How to accomplish the import, however, may be tricky. The fact that you mention that many users have distinct accounts on two existing sites will make your life more difficult, but not impossible. I believe @pfaffman has worked on importers, he might have some insight.

That’s quite simple - put them in a group, make a new category, restrict the category to that group.

Doable, but it will take some CSS work. See

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