To make things even worse: linker groups can include source inputs, not just arguments passed to the linker. Both clang and GCC seem to be aware of this and will compile the inputs, treating them as if they aren't inside the linker group. Real build systems rely on this!
Also it's pretty well known that the order of command line arguments passed to the linker is important. It is sometimes also needed to pass a library to the linker multiple times.
Depending on how you count, surely dd should take the cake? Otherwise, you're just including the group of commands that uses arguments as a command language, and I don't think that's actually such a small group; ffmpeg does the same thing, too.
So that is to say, each option which specifies some setting affecting files to the right of it on the command line is introducing a new version of the previous environment, in which that setting is altered, and the scope of that environment is the remainder of the command line.
I've been aware of picolisp presenting, IIRC, only an imperitive option.