Size of TreeUpdateResult is only 2 bytes. It can always be passed by value.
In this case it is used as reference and const. This is a bit redurant.
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TreeUpdateResult is currently very small, up that doesn't mean it always will be. Currently I see no value in passing it by value. Passing by const reference should be the default for structs and I don't see a reason to make an exception here.
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Also, it is stored by value throughout the update code. I'm not sure if this could be a confusion, since as far as I understand, the map that owns the original doesn't seem to change anymore.