Considering once again that the voltage between two conductors of two separate ungrounded systems may be higher than either system's voltage to ground
I think you are driving at an important point I didn't consider.
I assume you didn't mean to specify that the systems are ungrounded, as then there would no defined voltage to ground for any circuit conductor, and most likely no defined voltage between conductors of the two separate systems. [Although as far as I know there could be, i.e. you could connect L1 of a 480V ungrounded delta to L1 of a 240V ungrounded delta
So if you meant two separate grounded systems, your statement is true, but unremarkable. As the voltage between two ungrounded conductors of a single system typically will be higher than the voltage to ground of either conductor. So I imagine what you meant is that the voltage between a conductor of one system and a conductor of the other system could be greater than the L-L voltage of either system individually.
E.g. you could have a 480V corner grounded delta and a 240V corner grounded delta. Depending on how you do the corner grounding, you could end up with 720V between two conductors if you aren't careful.
So that raises the question, when 300.3(C) says "All conductors shall have an insulation rating equal to at least the maximum circuit voltage applied to any conductor within the enclosure, cable, or raceway," for the above example, does it mean at least 480V? As that's the maximum voltage of any intentional circuit. It doesn't say "at least the maximum voltage between any two conductors in the raceway," which is what I assumed.
If so, all the redundancy that electrofelon and I were discussing is gone. The 720V between conductors is handled by each one being insulated to at least 480V.
Cheers, Wayne