I'm pretty sure that a subset of a Borel set (in $\mathbb{R}$) of measure zero may not be Borel, but I don't know how to show it.
I do know that there are more Lebesgue-measurable sets than Borel sets.
I also know that every subset of a Borel set of measure zero is Lebesgue-measurable.
I would prefer a general argument (for example, using cardinality) over a counterexample.
This answer is inspired by Henno Brandsma's answer, and perhaps easier:
Any set of measure zero is contained in a Borel set of measure zero (since any Lebesgue-measurable set can be approximated from outside by a Borel set), so it suffices to show that there is a set of measure zero which is not Borel.
The Cantor set has measure zero and cardinality $\mathfrak{c}$, so it has $2^{\mathfrak{c}}$ subsets of measure zero. There are $\mathfrak{c}$ Borel sets, so there must be some set of measure zero which is not Borel.