A function can't really return a refernence. The return type of a function can be a reference type, but that just means that the function returns a glvalue. So maybe it'd be better to change [stmt.return].

I suggested in #5415, to say, the return statement should model a declaration T v = E where T is the return type of the function and E is the expr-or-braced-init-list of the return statement, and then say v is lvalue if T is lvalue reference type, xvalue if T is rvalue reference type, and prvlaue otherwise, such an invented declaration is a part of the full-expression established by the return statement, in this logic, the lifetime of temporary object created in the declaration is consistent with that of [class.temporary] p6.11. We can say the result of the function call is the v established by the return statement that transferred the flow control.

Maybe fixed by cplusplus/CWG#186