@Recent Convert - Wasn't the advancement in the new Canon 100mm f/2.8 macro hybrid the fact that it cold compensate for roll? I could be mistaken, I don't keep nearly so close to Canon news as Nikon, but if so, it shows it's doable at the lens level.
Canon's "Hybrid IS" compensates for pitch (camera tilted up/down), yaw (turning camera left/right) and also (that's the new part) for lateral movement. This is obviously of interest to the macro-shooters (a field I am fairly ignorant about). What it does NOT DO is correction for camera roll, which is "turning the camera around the lens axis". A lot of beginners initiate roll movements when they press the release. I'm not a beginner, but I can see the value of roll-compensation . . .
Let's quickly rehash to principle of in-camera VR (or IS): if you pitch your camera up, you grab more "sky". The corrective lens (close to the mirror) get's pushed down, to correct for that, and put more "ground" on your sensor. The left/right mechanism works accordingly. The lateral compensation also shifts the corrective element, but the algorithm requires two motion sensors that look for sideways movement (somewhat trickier to do, because it requires precise inertia measurement, while tilting can be accurately sensed by gyroscopic effects, though Nikon does not use a gyro, it uses inertial measurement as well). If the camera gets twisted around the optical axis, shifting lenses will not compensate. Instead, the sensor needs to be counterrotated (Sony does that). The major drawback: sensor movement is not visible in the viewfinder, but it could be observed in life-view.