Ga-Trojan. Please show me the regs to support that statement. Start with the beginning of the CARs
AIC H10/99 is pretty clear as to what is expected. I'm not a fluent with the CAO/CARs as I once was but I thought the CAOs had a reference to it.
You would have a hard time going to court and arguing that flight on a moonless night with no horizon is IFR. How can you log IF time when in the exact same conditions you could fly NVFR?
Also then what determines IF? Is the Takeoff IF time too? If so what are the operating minimas that apply there? The problem with saying that flying on a moonless night is IF is you create other problems.
It will all unravel in a big way if you have a incident and then there is some dispute over what flight time you have.