go test fails with "can't load package build constraints exclude all Go files"

You will only get that error if all the files in the package are excluded by your build constraints, not just the test files. If that's what you want, just add a single package file with no code and the package will still be able to be loaded. For example, many packages put their package level docs in a separate file, which you could use to always have a valid package:

// Package foo does foo
package foo