Btrfs, ZFS, and Apple's APFS all use exactly this copy-on-write-plus-reference-counting design to make snapshots instantaneous and clones nearly free, which is why `zfs snapshot` and Time Machine local snapshots return immediately even on multi-terabyte volumes. Forgetting to check the reference count before an in-place write is exactly the bug class that would corrupt a snapshot that's supposed to be immutable.