I had a quick look at there are quite a few differences between the
Delphix ZFS git repo and the upstream ZFS git repo. Github states: "This
branch is 376 commits ahead of zfsonlinux:master.".

So:

1. Does this issue occur with stock ZFS rather than Delphix ZFS?

2. With the activity you are performing to trigger the bug it does seem
like there is a race condition occurring on mnt_count so this does look
like a kernel bug.  One way to quickly sanity check this is with a
coarse bisect using some pre-build ubuntu kernels based on the mainline
kernels.

The wiki page https://wiki.ubuntu.com/Kernel/MainlineBuilds details our
mainline builds, you can select a mainline kernel from:
https://kernel.ubuntu.com/~kernel-ppa/mainline/?C=N;O=D - install it,
run the tests and see if the problem is fixed or still persists.  I
suggest trying a recent (say 5.1) kernel build, and if that works,
bisect on that between 4.15 and 5.1 etc until you find the earliest fix
point.

If the problem still occurs with a 5.1 kernel, then we need to start
digging a bit deeper. But I think it is definitely worth trying a recent
kernel first as the fix may be already be in an upstream kernel.

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https://bugs.launchpad.net/bugs/1832384

Title:
  Unable to unmount apparently unused filesystem

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