Why not EXT4?
Or Btrfs?
The technical advantages of ZFS over the (2) file systems you mentioned aside, because they would have been stuck with worse licensing issues (i.e. GNU GPL) than dealing with CDDL.
----------
Why couldn't Apple with its near $100 billion in the bank just outright buy ZFS if it's that good? I mean HFS+ can't be all that bad....
Not that I am suggesting that $100 billion USD is any small sum, but ZFS is owned by Oracle, and that is where primary development occurs.
I just don't see Oracle being bought out any time soon, either by Apple or anyone else.