I've been in communication with the upstream namespace maintainer, and
the intention was certainly that what you're doing should fail. However
there was an oversight that missed the O_CREAT case. Due to some
differences in 4.4 the backport did cover that case.

As I mentioned above, you can still do what your trying to do, you just
need to make sure your process's fsuid/fsgid are mapped into the
containers user namespace before creating the file.

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https://bugs.launchpad.net/bugs/1659087

Title:
  open(2) returns EOVERFLOW within tmpfs+userns

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