Chris, just to make sure I understand…
You are not suggesting that a dark frame acquired at Gain 0 on an ASI1600, which would be 4.88e-/ADU and a default offset of 10 ADU, would be the same as a dark frame acquired at Gain 139, which would be unity with 1e-/ADU and an offset of 10 ADU, are you? Since the offset is in ADU, it would be 10e- @ unity, while ~48.8e- @ Gain 0. So darks acquired at one gain setting couldn’t be used at another anyway.
Since read noise does drop at higher gain, and with dark current as low as it is (on the order of 0.005e-/s for most of these modern CMOS cameras), and with exposures being pretty short at higher gain settings, it is not necessary to use a large offset at higher gain. However, you do want to make sure you have a sufficient offset. An offset of 10 ADU is probably overkill for Gain 0, and an offset of 10 ADU is most likely insufficient at unity or higher gain settings.
Additionally, how you use the camera could play a role in how much dark current you have to account for in the offset. This could depend on aperture and f-ratio, how dark your skies are, etc. Someone using a large aperture fast refractor (such as myself, 150mm aperture on a 600mm focal length at f/4) is generally forced to use pretty short exposures across the board. Someone using a much slower scope, say a large SCT, might need significantly longer exposures to get a similar pixel signal. They would incur more dark current with those longer subs, so may need a different offset.
Fundamentally, we need the ability to optimize the offset with the gain, as a single offset isn’t going to pair well with every gain setting. Variable offset gives each user the ability to optimize the camera for their usage.