The BSDs, Solaris/Illumos, and Windows all have tried, some more than once even. I think there have been at least 4 Linux kernel ABI compatibility layers for those OSes. They've all failed. And all future attempts will fail too for the same reason:
The Linux kernel ABI is not
specified anywhere, and it's
insanely large (and growing).
Besides the system calls (easy), many ioctls (hmmm), proc(4) (oof), and many ioctl-like ABIs within ABIs, there's loads of driver-specific ABIs and things like security modules and what not that add their own ABIs and which you'll invariably end up having to support. The last effort in Illumos land foundered on proc(4), IIRC.To top it all off that undefined (but stable) ABI is a moving target: it's always evolving / getting extended.
The only thing you have to help you is that whatever the ABI, Linux [mostly] commits to maintaining backwards compatibility with it. If your compatibility ever gets good enough, that will help you, but in the meantime you'll be chasing a never ending and ever growing ill-defined ABI.
Good luck with that!