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I think the tag can only be applied to any properties that a client reports to the ePO server. If group membership is among them, the tags can be applied.
If not, well, there are 4 custom property fields in the ePO database for a computer, but as far as I know those need to be filled manually (ie. with SQL script or similar) to any value. They perhaps could be used to hold user membership data in some way....and referred to in tag criteria...
Thanks - clearly I have a lot to learn about ePO, but I will get there in time.