I'm not totally sure I understand the question, but yes, I believe what you are saying makes sense.
ng-cloak
is a bit different from other directives, because its only job is to remove itself. Angular does not apply any special styling to that attribute. It just removes it.
That means, for example, you could apply styling to make unloaded Angular elements have a background color, instead of being invisible. I don't know why you'd do that, but that's something to remember--it's just a boring old attribute until Angular removes it.
Behavior of loading CSS files is up to the browser, so it's probably fair to put a style tag in the head, but that's just like any other CSS resources--you rarely want elements loading without styles, and browsers are pretty good about avoiding that. I often like to put it in the head just for good measure, but I can understand someone not wanting to do that. But you definitely need it somewhere.
If you have JavaScript disabled, or before Angular loads, it's just like any other attribute:
[ng-cloak]{
display: none
}
<div ng-cloak>
Where am I?
</div>
But once Angular loads (no matter how long it takes to set up, simulated here by a one-second timer):
window.setTimeout(function() {
$("[ng-cloak]").removeAttr("ng-cloak");
}, 1000);
[ng-cloak] {
display: none
}
<script src="https://ajax.googleapis.com/ajax/libs/jquery/2.1.1/jquery.min.js"></script>
<div ng-cloak>
Here I am!
</div>