I’d hope at least {{Tags}} works, since that’s given as an example for using Conditional Replacement – Card Generation - Anki Manual .
Looking at the others – I find myself wondering if Special Fields are meant to be used this way. There might be a justification for treating {{Tags}} differently – since it’s more like an actual field – while the rest are a way to display something that is definitely not a field.
If we use {{#Tags}}{{Back}}{{/Tags}} then adding a note with or without tags creates only one card, despite the second being nonempty in the preview. In this case, the empty cards tool does find the empty cards (if there were any card 2’s before changing the template).
If we use {{^Tags}}{{Back}}{{/Tags}}, then a second card will be created regardless of having tags or not. The empty cards tool fails to spot these cards.
It’s probably assuming that the note has no tags when creating cards or checking for empty ones.
I see your point, but it’d be a handy way to disable card types and wouldn’t hurt the average user.