ZFS is a copy-on-write file system; that means that on-disk data is never updated in-place: every time a block of data is modified, it is effectively copied to a new location. So for writes, this will inherently negate any auto-tiering.
Furthermore, I seem to remember reading somewhere (Ars?) that the HFS+ layer uses CoreStorage-specific IOCTLs to actually initiate the tiering; if that is indeed the case, ZFS will never generate these, and the net effect will be that you have ZFS running on what is effectively a concatenated device with very non-uniform performance characteristics (depending on whether any given block address is located on the SSD or the HDD).