LifeHacker points to an article that demonstrates how to get Snow Leopard running inside a VMWare instance on Windows. Of course this is just the sort of thing that got Psystar into hot water, but then again it they were not doing it as an academic exercise. It should be possible to generalize the instructions for VirtualBox running under Ubuntu or even Mac OS X. If anyone finds an article along those lines, please leave a comment.
In order to get Snow Leopard working in VMware, you’ll need to be on an Intel-based Windows machine (AMD currently isn’t supported) with a retail copy of Snow Leopard, as well as a Snow Leopard VMware disk file, downloadable from many sources (iHackintosh lists a few).