Since both are equivalent in the usual context, I looked at the source and was changed from the form you offer to the current form 2 years ago, with the following comment:
"Added a clear definition of the global context of compatibility with Adobe JS"
https://github.com/jashkenas/underscore/commit/aa916b8cfe565dc206d85c4cb74fbb6c499067a7
The logs for the first version of Underscore with this change say: "Improved compatibility of the subtree with the Adobe JS engine, which can be used for script Illustrator, Photoshop and friends."
http://underscorejs.org/ Version 1.4.3
So, this change was made because the Adobe JavaScript engine did not match ES3 or ES5 at the time, but Underscore was compatible with this change.
If you do not plan to run your module in Adobe JS, you can use any of these forms. If you later, then Adobe JS requires the form used by Underscore.
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