Sure, but if the copyright holder is a foundation, you actually need some legal representative to put that in writing, a single dev writing something on GitHub wouldn't mean much, even if they are the sole maintainer.
IANAL that seems to be a distinction without a difference.. you say yourself "the copyright holder" then make a gray case about some entity holding legal ownership that is not the copyright holder.
first to say, the interpretation will be different in different legal regimes, but.. here in the USA, I believe that the copyright holder is the title that determines who gets the say about changes to the license.
Sorry, I should have been more clear. I meant that it is fairly common for a project that has a single author and contributor to nevertheless be developed as part of an organization such as Apache. So, even if that single author is the de facto owner, they may not be the legal owner of the copyright.