I do not see how that would work. Do you imply loan is getting foreclosed at some point and bank takes collateral from the offshore bank? In that case US subsidiary will pay full-rate income tax on the foreclosed amount..
Unfortunately, I cannot find that article. IIRC, the loan never gets foreclosed. It's like the bank is receiving an interest as a fee for the service of tax-free repatriation. If I had time to analyze this further, I would take top 5 tech companies I compare their long term debts with their off-shore holdings (or estimates if not available).