Several requests have been made over the years for a way to end a subsection without starting a new new higher level section. This is possible with plain lists: a blank line ends the list. Some other syntax would have to be added to org to allow this for sections. I would love to see something like this implemented:
--- begin org example --- * First top-level section A bunch of text. Blah blah. Yada yada. ** TODO Something I need to do ** :END: Resuming first top-level section. ** Here is a small subsection When this sub-section ends, the top-level section will resume. ** :END: Resuming first top-level section. --- end org example --- Such a fundamental change to org syntax might be difficult to implement without extensive changes to how files are parsed. But, IMHO, it would add to its elegance and flexibility. As things stand now, inline tasks and lists are used as workarounds.