I hadn't realised this, thanks.
> the three cards will never be the first cards out of the shoe
Does this matter? I'm using a model of "the dealer's other card is equally likely to be any of the cards except the two I have and his face-up one", and it doesn't matter where those three were originally. The model can be improved by counting cards, but it's still strictly (albiet very slightly) more accurate than the model of "the dealer's other card is equally likely to be any of the cards in the deck/shoe".
But perhaps there's something else about Blackjack that I'm not aware of?
You're correct about your other objections, and 15/49 is indeed harder to work with - but "without actually making it more accurate" is false under the one-deck assumption. It is not wholly accurate, but it is more accurate.