It depends on the implementation of the JavaScript engine. One engine might allocate memory for the variable in the first example and not allocate memory in the directly-passed example, while another implementation might be smart enough to compile the code in such a way that it makes the first example not allocate memory for a variable and thus leaves the first example behaving as the directly-passed example.
I don't know enough about the specific engines to tell you what each one does specifically. You'd have to take a look at each JS engine (or ask authors of each) to get a more conclusive answer.