It may be worth taking a step back and asking who the users are.
I know that like most folks on HN, I am not your average computer user so my view is probably a bit different. With that out of the way, I can say that I firmly prefer folder hierarchies for organizing my files over tagging. I switched to MacOS when I started my new job, and the fact that tagging is such a integral feature out of the box over plain folder navigation irks me. It's easier to save a file to the correct spot in the hierarchy and find it later rather than searching by tags to me.
Perhaps my view isn't consistent with a lot of computer users, but I will say that most people understand how hierarchical filing works better than tagging as one is more spatial than the other. After all, there is a reason that the memory palace technique for recall relies on imagining a physical space.
A hierarchy is actually a tag, so really what you're saying is you firmly believe in only having a single tag for each file and a specific adhoc schema for those tags. I think once you've used a filesystem that behaves in more complex ways you start to realize that's not necessary. For example with a snapshotting filesystem you add dates and times to the path in order to access older versions of files. I don't really use MacOS but I have noticed the tagging in my limited experience with it, which seemed reminiscent of what the old MacOS used to do where you could set icon colors. So whatever they're doing for tags isn't really the only story. MacOS is a good example though because that is a filesystem that maintains separate metadata in addition to the file contents (they used to be called resource forks, but I'm not up on modern MacOS). Many linux filesystems also can support that sort of thing. But those are just flavoring the files and not really adding different ways to index into the filesystem. A hierarchical index such as nested folders is probably a minimally viable solution and is very useful. But that doesn't mean it's not limiting and that there are not different larger solutions that achieve more useful results. Once you start thinking about snapshots and transparent de-duplication and other ideas like don't-repeat-yourself things wind up becoming far less clear.
