"The distinction between passing the value of a reference being used by the caller and passing a reference to the caller's stack is so rarely important or useful that there's no consensus terminology for it."

And the reason for that is essentially all modern languages make copies of something when passing argument parameters. The only question is what they are passing and exactly how hard the language layer works to make it look as if you are or are not passing something by reference.

I have to reach to something as obscure as Forth to find a language that does not work that way, and truly does not copy parameters into a function. (I haven't dug into Factor enough to know if under the hood it still copies parameters.) It's a very unusual choice to not copy something for a function call.

(This is one of the ways our CPUs have been optimized for the languages we run; they make this intuitively expensive operation otherwise cheaper than it would be on a naively designed CPU.)