With the "you left me to die" line and the seeming redemption in the final moments of The End Of Time it has to be a possibility.

I expect it to be that John Simms Master didn't end up in Gallifrey and died/almost died on Earth.

Or that Simm's Master did end up on Gallifrey - but since he was 'saving' the Doctor he expected the Doctor to stop him from ending up going back with Rassilon.

The death could be the body dying on earth, it could be Rassilon killing him, or the fact that at that time Gallifrey was expected to be destroyed. 'You sent me back there to die'.

I think that it would be a little confusing for viewers to show a master from before the last time we saw him. I think there would have to be a really, really good story reason for them to consider it, because otherwise I doubt they would choose to make the story needlessly more complicated.

At the end of Survival the 7th Doctor leaves the Master to die on the Cheetah planet. That is the last he is seen until Dr Who The Movie where it is evident that some 'time' has passed in his timelines(s). Could that Master be the one who becomes MIssy and not the Master last seen on his way to Gallifrey with Rassillon?

I thought it had been established (or at least, never contradicted) that the Doctor and Master always meet in chronological order, regardless of how unlikely it is.

I think they have with the obvious exception of The Five Doctors

If it suites a story device then I'm sure they will meet out of chronological order. We are talking about a pair of Time Lords.

It could be the opposite and a future Master punishing this Doctor for something he hasn't done yet.

A pre-YANA incarnation would lack tension. After all, the Jacobi and Simm Masters would have gloated about the Doctor's terrible fate if they had defeated a future Doctor in the past.

The Master is 'a little bit' psychotic so I'm guessing his being left on Gallifrey (or somehow being left behind on Earth) and dying somehow would be enough to tip him/her further over the edge. The Doctor did 'save' Gallifery and strand it in a 'single point of time' so maybe this is what he/she is referring to and is peeved that the Doctor didn't pick him/her up before he returned.