So in theory when leopard comes and I want to change file systems to ZFS... would I have to do a clean install or would it just be able to change through an upgrade?
Although it's looking like ZFS will be supported, we don't (as far as I know) yet know whether it'll be the "preferred" filesystem or a niche one (like UFS is now). The best idea is to wait and see what happens.
I'm certainly interested by ZFS - I seen to remember reading something about how its implementation would be good for snapshot backups like time machine but I may be making that up.
If moving from HFS+ to ZFS would require a reformat that would be pretty tricky! I've got two externals full of data which I guess I would have to move elsewhere while I reformatted