If ZFS was re-licensed to be compatible with the GPL, then I'm sure that it would get accepted into the kernel (assuming the code is tidied up as necessary). Now it can be argued that CDDL and GPL are compatible, but that's a risk and Oracle have been known to be litigious whenever it suits them.
From: https://opensource.stackexchange.com/questions/2094/are-cddl...
> The CDDL is a license that does not try to enforce restrictions that would not stand in court but disallows relicensing of code. The fact that on the other side, the CDDL explicitly limits its scope to the files that contain CDDL'd code, allows us make our first conclusion:
> Code under the CDDL and code under the GPL cannot be mixed in a single file.
>The GPL is a license that limits its scope to the so called "work" limit and forbids relicensing of code. This allows us to make the next conclusion:
> Code under the CDDL and code under the GPL cannot be mixed in a single work.
So, that would seem to leave two options - either re-license Linux under a CDDL-compatible license or re-license ZFS under a GPL-compatible license. Clearly re-licensing ZFS would be much easier as it's controlled by a single entity - Oracle.
My opinion is that Oracle are acting in bad faith (probably a default assumption with Oracle to be fair) and deliberately don't want the code to be in Linux.