Return by value. The compiler can optimize away the copy, so the end result is what you want. An object is created, and returned to the caller.
I think the reason why you rarely see people do this is because you’re looking at the wrong C++ code. 😉
Most people coming from Java feel uncomfortable doing something like this, so they call new all over the place. And then they get memory leaks all over the place, have to check for NULL and all the other problems that can cause. 🙂
It might also be worth pointing out that C++ references have very little in common with Java references.
A reference in Java is much more similar to a pointer (it can be reseated, or set to NULL).
In fact the only real differences are that a pointer can point to a garbage value as well (if it is uninitialized, or it points to an object that has gone out of scope), and that you can do pointer arithmetics on a pointer into an array.
A C++ references is an alias for an object. A Java reference doesn’t behave like that.