I am not sure that is the reason. Apple did already announce it at WWDC after all. ZFS on OS X was announced in June 2007. In September 2007, NetApp sued Sun over patents violations in ZFS.
It's likely that Apple didn't want a patent suit after adopting ZFS as their main file system. 2007 Apple was of a completely different size as 2014 Apple.
ZFS support made sense for Mac OS X Server back in 2007. It's a beefy server filesystem that rewards beefy servers with gobs of ECC RAM, RAID, and no battery to worry about.
ZFS as default replacement for all of Apple's HFS+ usecases (laptops, iPods, phones and tablets in the works) made no sense in 2007 and makes no sense in 2014. ZFS is simply too resource intensive and too dependent on ECC RAM even now for consumer use cases.
All other filesystems are equally susceptible - if your memory is getting errors, they'll happily write those to disk too.
But it can't prevent a bitflip of data in memory from getting written to disk before the checksum is calculated. Nor can it prevent data being bitflipped after its been verified and handed off to the application.
Which I'm pretty sure XFS can't do either.
It may have been great if Time Capsule, or an Apple NAS uses ZFS. But it seems Apple will likely wants you to move everything to iCloud Drive( Finally! ).
I think Apple's new FileSystem will be based entirely for Flash. Something similar to Samsung's F2FS. Since F2FS is GPLv2 license it is not possible for Apple to use it within their own Kernel.