I suppose, but most of the times loopholes aren't like that.
Either they are intentional things that have unintended consequences or they are unintentional things that people didn't realize what they meant.
Sometimes they are just laws that are working as intended but somebody doesn't like them so they are labelled as a loophole.
I think there are very few loopholes that people intended to create by intentionally phrasing it weirdly.
I think there are more such loopholes than most people realize.
From The Blind Spot: How Oligarchs Dominate Our Democracy by Jeffrey Winters: "When it comes to winning advantages for wealthy and powerful clients, lobbyists focus in on micro-details no one else is paying attention to but which could mean millions or billions saved by clients. 'Sometimes we were changing a word and that's all that we needed,' one lobbyist admitted."