$ find ~/ -mindepth 2 -type d | wc -l
This indicates that (even not counting the base level of the hierarchy to avoid counting all the .config/ directories), I would have to deal with a flat list of 20575 tags. On the other hand, in each directory I most of the times do not have more than about ten or twenty objects (some may be directories).
Using a flat list of tags works well if their number can be kept reasonably low. Once their number grows, hierarchy becomes useful again (gmail uses hierarchical tags for instance).
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