I thought this was playing audio not streaming it. A streaming app would need both background network access and the ability to play audio in the background. See the Background Audio section at http://developer.apple.com/iphone/library/documentation/iPho.... It is not clear here that network access is permitted. Being vague in the permitted application functions for each mode makes it difficult to know what exactly os permitted.
It's completely clear that network access is permitted because Pandora uses it, which is the app everyone thinks of when they think background audio. It also works for Rdio and many other apps.
Audio streaming applications don't need the the voip setting. The somewhat tricky idea is that as long as a background-audio-marked application keeps playing audio its process won't get suspended and so it will be able to do whatever networking it needs.