The DOM is garbage collected, you cannot hold a reference to a DOM element in a non-garbage-collected environment without having to manually mark as held and free.

Remember that some old IEs had memory leaks because one could make circular references through the DOM and JavaScript, and they each had separate garbage collectors. Well working garbage collection is not an afterthought, and you can't get two distinct garbage systems to work together in the seamless manner that a single system can operate.