I ran into this exactly as smoser described using using overlay in a
container that is backed by zfs via lxd.  I believe this will become
more prevalent as people start to use zfs root with Focal 20.04.

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https://bugs.launchpad.net/bugs/1718761

Title:
  It's not possible to use OverlayFS (mount -t overlay) to stack
  directories on a ZFS volume

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