joyent/libuv — comment on commit 85856a6f01ac6e349f787ad1e51ffb8664d76b3d
File: src/win/handle.c line 182
By igorzi:

People might expect their close callbacks to run through. And in some scenarios it's possible that close callbacks will do something to increment the refcount (e.g. create a new tcp connection), which would have kept the loop running.