I can label XREF Parcels.
I can label XREF Pipes and Structures (aka Parts) without incident... And since DREF Null Structures do not retain their Source Style assignments, I am relegated to either XREF, or duplicating work (so XREF wins)... So why not _any_ other Object?
Another example, is an XREF Alignment, which I can label... Sort of.
I can use Station Offset labels with Profile reference component to show Profile Grade, but I cannot label a Segment with Profile reference component, and select the XREF Profile directly... I have to select another Profile (or <none>), and then go back and manually select the XREF Profile from the Properties Pane, which is also just dumb.
Users should be able to label any, and all Civil 3D Objects in the active document, or its XREFs, and those labels should not 'go away' because a layer is Frozen.
Separately, whoever came up with the idiocy that allows labels to remain when a layer is Off, but not Frozen, deserves a kick in the... I'll say 'Pants'. Grrr