Earlier quoted context omitted.
Not true! ZFS also normalizes. However, while HFS+ normalizes on _create_ (bad), ZFS normalizes on lookup (good). Specifically, ZFS has a normalization-preserving, normalization-insensitive behavior -- a lot like case-preserving but case-insensitive behavior, but for normalization forms rather than case. The way this works is that there's a) a string comparison function that can provide normalization- and/or case-ins…
That's fascinating. What happens on lookup if there's two different files with canonically equivalent names?
Say you create a file with a name that has different NFC and NFD forms, and you create it with the NFC form. Then you go try to create it with the NFD form, well, if doing an exclusive create (O_EXCL) then you'll get EEXIST, else you'll open the existing file.