You might also be interested in MacFUSE, the Mac port of the File-system in USErspace project. It allows one to write filesystems pretty easily (though with lower performance than native file systems, naturally).
One of the demos is a Spotlight file system, which in combination with the tagging using Spotlight comments could presumably create a tagged filesystem in Mac OS X:
http://googlemac.blogspot.com/2007/01/spotlight-file-system-for-macfuse.html