Right, and on the flip side, Forth on say x86 will inevitably involve passing a pointer to the stack, be it explicitly or implicitly (ie global variable).

So if one invokes low-level implementation details, Forth is also a pass-by-pointer-value in the same way as C# "ref" and others, at least on x86.

However I don't think appealing to implementation details is useful, what matters is what is observed through the language, with the results you point out.