Using the most common definition* of dBFS, a -0.1dBFS sine wave (by definition) does not have any inter-samples that exceed -0.1dBFS. Stereophile does 0dBFS testing at 1kHz and/or 50Hz for digital products. Almost all products easily do >-80db@50hz. The only one I've seen that sucked bad was the Dragonfly near full scale. *AES17-1998 3.3-3.4 (page 5)
I appreciate the detailed response. Yes, I am aware signals are reconstructed and reconstruction of some signals can generate "overs". But a sine wave <=0dBFS is not such a signal. The definition of 0dBFS sine wave is one that kisses the positive max, but never touches the negative max. A full scale sine wave does not "over" in reconstruction.
I'm led to suspect that the digital signal being fed to the DAC has itself been distorted by a conversion error, a level error, or some other OS/driver processing that has kicked in.