why not

if (branch(old_dentry) != left_most)
        copyup();

vfs_rename(old_dentry, new_dentry);
create_whiteout(old_dentry);

would seemingly simplify it a lot, negative is that a rename() would create a copy even if source is on a rw branch.

The question is rename() more similar to a "file modification" or a file creation/unlink. if it's the former, the current hoops make some sense, if it's the latter, the simplified version would seemingly make more sense.
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