This has imho nothing to do with Windows 10 but 3dsMax and Corona combination and was written about sufficiently to prove it.
Your memory consumption (of the combo) will rise after subsequent rendering (normal or IR) and won't get back. Corona can't flush all the data.
This has been proven times in comparison to Vray.
It usually isn't 'too big' issue since Windows will swap data around during the early rendering part (usually precomp, which is when mem consumption rises to astronomic values), but usually is problem with final high-res rendering.
I have 64GB memory, but when I do final 8k rendering with displacement, I have to restart 3dsMax if I need to restart rendering because of something I forgot. The second rendering would run out of memory that wasn't flushed back after quitting and displacement/GI precomp/etc... would just take forever while Windows would be trying to swap data that 3dsMax would be hogging.
I've seen the fault is being given to Autodesk since Corona can't force it clean up everything but still, it's the combo that is power-hungry.