I don't think it's to do with the firmware, i think it's to do with the logic boards that they use.
See this
document on the Santa Rosa chipset from Intel. Page 2, second column.
Apple has firmware-restricted its computers in the past. For example, both the first gen Intel Mac Mini and current Mac Mini are based on the same chipset (Calistoga). The only difference between them is the former shipped with Core Solo/Core Duo, while the latter uses Core 2 Duo. Both chips can address >3 gb of RAM, but the the CS/CD controller was EFI (firmware) restricted to two 1 gig SO-DIMMs. If you put more than a 1 gig SO-DIMM in either slot, the computer will not even boot.
The current Minis do not have this restriction. You can put 1/2 gig chips (i.e., 3 gigs) or 2/2 gig chips (i.e., 4 gigs) in its two SO-DIMM slots. Either way, you have access to 3 gigs (or 3.1 gigs with 2/2 gig) because the chipset can only access that much (32 bit). (Edit: Even Apple's
web site lists only 2 gigs as the limit for the Mini, which is clearly not the case.) The Santa Rosa is 64 bit, thus can address 8 gigs with its memory controller (according to Intel). The cpu has nothing to do with it because you can put a C2D chip into a first-gen Intel Mini and you still are restricted to 2 gigs max.