This sounds wrong, are you sure? Would you mind demonstrating with an example on godbolt? Whether NRVO applies or not, the ABI should be the same, AFAIK.
I will say before testing this i didn't realize the RVO calling convention was to return the pointer you pass in, but apparently so. If makeS2() returned void, it's just a tail call to the constructor, but makeS1() has to spill rbx and use it to save the pointer.
The reason this should sound dubious is that you're suggesting the caller needs to know the callee's body in order to know how to call it, but it should be possible for the two to be compiled entirely independently, and in fact mutual recursions should be fine too. After all, the callee knows where the return value has to land either way, and the caller similarly knows where to expect it, regardless of when/how the object is constructed or destroyed.
https://godbolt.org/z/9WvnEvEYh Note how `std::unique_ptr<int>` effectively passed as a `int**`; and that the by-value unique_ptr is not destroyed at the end of the function -- destroying parameters is instead the caller's job (and commonly only happens at the end of the full expression containing the call -- though this choice is implementation-defined). But that can only work if the caller can see the updated value of the parameter (to avoid double-free for `clear`) -> thus the need to pass the parameter by hidden pointer.