This isn't going to be trivial to fix, it would require the vm to provide a different taylored scope to each function.
IE used to not GC cyclical JS/DOM references. Google Chrome is doing a massive rework of DOM garbage collection with Oilpan.
You are right that it is not a trivial change, but there is nothing technically infeasible about GC'ing per closure. I think it is worth it, just as it was worth it for IE to have smarter GC.