I think we might be working with different definitions of the term "causal structure"? The way I see it, what matters for whether or not two things have the same causal structure is counterfactual dependency - if neuron A hadn't have fired, then neuron B would have fired. And we all agree that in a perfect simulation this kind of dependency is preserved. So yes, neurons and transistors have different lower-level causal behaviour, but I wouldn't call that a different causal structure as long as they both implement a system that behaves the same under different counterfactuals. That's what I think is wrong with your GIF example, btw - there's no counterfactual dependency whatsoever. If I delete a particular pixel from one frame of the animation, the next frame wouldn't change at all. Of course there was the proper dependency when the GIF was originally computed, and I would certainly say that that computation, however it was implemented, was conscious. But not the GIF itself, no.
Anyway, beyond that, we're obviously working from very different intuitions, because I don't see the China Brain or Turing machine examples as reductio's at all - I'm perfectly willing to accept that those entities would be conscious.
It's unclear why counterfactual dependencies would be necessary for machine functionalism, but ok, let's include them in the GIF example. Take the first GIF as the initial condition and let the (binary) state of pixel, Xi, at time step, t, take the form, f(i,X1(t-1),X2(t-1),...Xn(t-1)). Does this make it any more plausible that the animated GIF has human consciousness? If you think the GIF has human consciousness, then what is the significance of the fact that the system of equations is generally underdetermined? Personally, it's not plausible that the GIF...
Recently published article in Nature Methods on a new protocol for preserving mouse brains that allows the neurons to be traced across the entire brain, something that wasn't possible before. This is exciting because in as little as 3 years, the method could be extended to larger mammals (like humans), and pave the way for better neuroscience or even brain uploads. From the abstract:
http://blog.brainpreservation.org/2015/04/27/shawn-mikula-on-brain-preservation-protocols/