MSA, you're right with the reference. I wrongly assumed it's the IR flight test that qualifies. That being said, I do know guys who did what Jurassic states. PPC in the level full flight simulator for the ATPL. Is your response from the HQ licensing folks?
About the 'based on a foreign licence', the FAA/TC agreement says that both authorities check with each other how the licence was obtained. So I'm not sure what constitutes a 'full' licence. Cheers.