scrub out on vtnet1 proto udp from any port = 33333 to any port = 1195 set-tos 0x20 fragment reassemble
scrub in on vtnet0 proto udp from <VoIP> to any set-tos 0xb8 fragment reassemble
I was finally able to get the 0xb8 tagging working again by finally specifying a destination on the WAN out rule, which, it should have matched merely on the destination port 1195 (I added the source port, tested, then added the destination as a last resort)