In Go, it’s a question of who owns the allocation. If you return a pointer type allocated within the function, the answer is “no one,” so the pointer escapes and has to be managed by the garbage collector.

If the allocation is owned by the calling function which uses it internally and then doesn’t return it, it can be a stack variable. Or the same allocation can be reused many times in a loop. Or an array of allocations can be made all at once with foreknowledge of the total number.