I think there may be a misconception here: A tail call is NOT a call that doesn't allocate a stack frame. A tail call is a call that is the return value of a function. This is why we refer it the stack frame-eliminating optimization as "tail call elimination". We are taking a jump-to-subroutine (call) instruction and replacing it with a normal jump instruction, thus eliminating a "call" from our program.

The JVM most certainly does support general tail calls through its invoke instruction, which supports calls to arbitrary methods of arbitrary objects (which, of course, includes tail calls).

Some compilers also support the optimization of _some_ recursive tail calls (usually recursive tail calls to final or local methods) into loops using the goto instruction, which supports jumps within the current method (essentially optimizing the tail-recursive method into a non-recursive method containing a loop).

Scheme implementations will compile any tail calls into jumps, even if they're mutually recursive. This is easy to understand by doing CPS transformation by hand on such calls.