I am aware of that, this was a sidestep based on the comment about FSDO inspectors.
I also do not agree with the Letter of Interpretation mentioned earlier.
It seems to contradict the inspector guidance in FSIMS under D(3)
(my highlights)
3) Determining Equivalent Rating. In some cases, determining the equivalent rating may be difficult. Several foreign countries categorize pilot ratings and limitations by horsepower or engine type. The FAA ASI (Operations) or AST should contact AFS‑810 at 202‑267‑8212 if in need of assistance. However, the limitation by horsepower or engine type is not required to be placed on the U.S. pilot certificate, because § 61.75(e)(3) requires the pilot to adhere to the limitations of his/her foreign pilot license even when exercising the privileges of his/her U.S. pilot certificate.
This clearly states limitation 'of a license' vs limitations 'on a license'.
So in the case of Victo my
opinion is that he can only fly night in the US under IFR so on an IFR flightplan, albeit in VMC conditions.
Which means he would need to have his IR added to his 61.75 by taking the "Foreign Pilot Instrument Written Test".