Description:
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functions implemented in a C extension can't return
by reference while native PHP functions can
(although one would expect that you can do *more*
with a function implemented in C, not *less*)

this first came to mind when someone requested
func_get_arg() to be extended to fetch parameters
by reference so that you can implement PHP
functions that take a variable number of parameters
by reference ...

there seems to becode somewhere in the Zend Engine that
always de-references return values ...?