If CDDL did not have their condition that source code is only made available under CDDL license, then the incompatibility would not exist. If GPL had similar loophole as CDDL and permitted modifications to be under different license if they are put as a separate file node in the file system, then the two permissions would permit a single project to include software under both licenses. I doubt CDDL will receive such update, and there is already LGPL.
The loophole is quite interesting from a legal point of view. Would a filesystem based on a database be fine? The computer would be storing all the code in a single file, but the presentation would look like that file is actually two different ones. Same goes with a gz file and "virtual" file systems, that present data inside as if it were separated files on the disk. What about a container image where a single work has source code under CDDL and source code under some other license?