Is Visual Studio 2013 optimizing correctly in the presence of /OPT:ICF?

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This does not seem like a valid optimization according to the draft C++11 standard section 14.8 [temp.fct.spec] says (emphasis mine going forward):

Each function template specialization instantiated from a template has
its own copy of any static variable. [ Example:

template<class T> void f(T* p) {
static T s;
};
void g(int a, char* b) {
    f(&a); // calls f<int>(int*)
    f(&b); // calls f<char*>(char**)
}

Here f(int*) has a static variable s of type int and
f<char*>(char**) has a static variable s of type char*. —end example ]

Since your taking the address of the variable folding them effects observable behavior which would violate the as-if rule.

T.C. points out that /opt:noicf prevents the non-conforming behavior.

Matt McNabb points out that the /OPT (Optimizations) documentation contains the following note:

Because /OPT:ICF can cause the same address to be assigned to
different functions or read-only data members (const variables
compiled by using /Gy), it can break a program that depends on unique
addresses for functions or read-only data members. For more
information, see /Gy (Enable Function-Level Linking).

Which suggests this could be intentional non-conforming behavior. Ben Voigt says in a comment now moved to chat that this indeed means the optimizations can be non-conforming but this points is debatable.

User usr linked to an MS blog post: Introducing ‘/Gw’ Compiler Switch and it says:

Please note, the ICF optimization will only be applied for identical
COMDATs where their address is not taken, and they are read only. If a
data is not address taken, then breaking address uniqueness by ICF
won’t lead to any observable difference, thus it is valid and
conformant to the standard.

and a later comment says:

Even though it’s on it’s own completely standards complaint, when
combined with /Gy potentially breaking behavior can result.

From what I can tell in order for /Gy to effect const variables __declspec(selectany) has to be used but it could be clearer in the documentation.

At minimum we can see that /Gw should not introduce non-conforming behavior but /Gy in combination with /Gw may.

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