It can be done using two Forest objects: one for the foreground and other for the background.
To adjust the density, use Camera->Distance Falloff->Density with two opposite curves.
I attach a sample scene (Max 2010), in this case using boxes, but applicable also with 2D and 3D trees (just assign the plants in the Geometry List).
Note: it is recommendable to use different General->Random Seed values, to avoid duplicated items in the overlapped areas.