Not really. Unless the reference is a member of a class and you allocate an object of the class on the heap, giving the reference to the constructor, the reference has to be a local variable. Since the object can go out of scope, it's gotta be a local variable too. Since references have to be bound at initialization time, it's guaranteed that the object lives longer than the reference. And if you do the whole allocation thing, it's your code that won't pass review.
You also have the potential of a dangling reference if the object goes out of scope.