IMO main current advantage of ZFS over btrfs is RAIDZ for pools, RAID5/6 on btrfs is still experimental and not ready for production, but using a ZFS pool would negate unRAID main advantages over FreeNAS, like using full capacity from different sized disks, possibility of adding or removing disks from the array, etc, since unRAID uses each disk as a separate filesystem btrfs is as good option, and don't forget that unlike btrfs, ZFS has no filesystem repair tools, if a disk turns unmountable there's nothing you can do, and although rare it happens, you can see that on the FreeNAS forum.