Most smaller or behind the meter systems such as carports or rooftop mount solar use fixed tilt, and fixed tilt is also used in certain types of terrain or where costs for tracking are prohibitive.
Horizontal Single-Axis Solar Tracker’s are normally aligned north south, but shifting slightly off axis from pure north vs south can increase output in the morning or evening.
Tilted Single-Axis Solar Tracker’s are closer to the performance of dual Axis trackers, but have a similar question do you pick a tilt angle to maximize annual, summer, or winter output.
The repositioning of panels to capture more morning and evening light is a real thing. At the theoretical extreme it can make the PV output a square wave.
But, that actually makes the duck curve worse, since the duck curve is about the gradient of that switchover.
But the duck curve has never really been an actual problem so it's kind of academic. And if it was we have solutions to it.
To simplify if nuclear/geothermal or whatever was 10c/kWh if sold 24/7 but if wholesale prices are 1c for 8 hours a day then base load generation needs to make up 8x9c = 72c over the other 16 hours. Now prices would hypothetically jump from 10c for those 16 hours to 14.5c for those 16 hours.
It should still be a net savings for the average consumer, but if your business model is based on cheap electricity at 10am to 4am that might flip to 10am to 4pm.
I hadn’t thought of it until just now, but that should flatten the duck curve.
Another way to flatten the duck curve is to buy smaller inverters and more panels.
So, 20% more cost for 10% more power could be worth it even outside of space constrained applications.