I'm aware that returning $fh instead of <$fh> would keep the file handle open. I just wanted to confirm that the normal scoping rules also apply to <$fh> and there is no evil magic trickery going on behind the scenes.

What kind of evil? Hmm. Maybe <$fh> is actually evaluated lazily and does not return stuff unless someone actually reads from it keeping the $fh open. (Sorry, to much functional thinking recently...)