The tops can take the heat so long as the roots do not.
Given what I've seen in the past (and as recently as yesterday) while repotting several trees, the reason Bill and Vince's trees do not absolutely bake in black containers is 2 fold. First, they are growing in more temperate climate. Even on days with intense heat, it does not last all day. Also, the night temps get relatively cool. Second, is the size of the container. With the short duration of intense heat/sun, the growing mix does not get hot all the way through. The same container without shade in the south will absolutely bake and stunt (even stop) the growth of the tree. Also a smaller container would get too hot throughout the container yielding the same results.