An interesting point raised by Morgoth's Ring is that corrupted Elven spirits may "answer Morgoth's summons" and go to him rather than to Valinor. Presumably these corrupted elven spirits could not be counted on to refrain from breeding during time of war nor from not returning more than once from death, both of which are customs rather than hard rules for elves. Indeed, an evil Yrch might delight in returning over and over again to spite those that he fights. Imagine facing a squad of elite "storm-orcs" that literally have nothing to lose: they know they're coming back while their human enemies die forever. Not fun.
It's an interesting idea but I doubt that Sauron and still less Saruman could issue the "summons" so it still leaves some orcs immortal (perhaps only to the end of the first age when Morgoth is banished?) and most not.
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