Glad you figured it out, I suspected this had something to do with the
may_create/may_o_create code paths but couldn't wrap my head around it.
Hopefully this will be addressed upstream in the near future.

This change in behavior is surprising though, maybe this should be
documented in user_namespaces(7).

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

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

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