I just tested the Apple TV 2.17 (15246) client with an unmodified file, and the HEVC stream plays normally when “Use Old Video Player” is disabled in settings.
From the release notes:
- The Enhanced Video Player is now available to all users and enabled by default. It can be disabled at any time from the app Advanced Settings.
- Fixed stuttering when playing videos with the Enhanced Video Player on Apple TV 4th gen.
I consider this to be resolved, at least on tvOS.