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Subpixel AA rendered to transparent surfaces needs component alpha to not look bad. Graphics backends do not support component alpha in a performant way.
Retained layers made us use transparent surfaces a lot more, e.g. when content without an opaque background is being scrolled.
The rules for whether a transparent layer with text needs to be non-retained vary by surface type. Some backends (Quartz, XRender, GDI) can draw subpixel-AA text into a transparent surface with full fidelity as long as it's all over opaque pixels. Other backends (D2D) cannot draw text into transparent surfaces without losing fidelity, even if the text is all over opaque pixels.