I spoke briefly with an accountant and he mentioned that the controlled foreign corporation rules might make it difficult to go this route.
From the quick perusal of those rules it looks like any gains made by the corporation have to be paid by the US citizen as if all income were to be distributed that year as opposed to any long term deferred income.
Now, considering the bitcoins are loaned...it does not seem like that would count as a capital gain. The loan is a debit while the total cash is the equivalent credit. But if that were the case, the company would not need to be a foreign company since even a US company with no capital gains would not pay taxes.