Does an IPC count as a BFR?

Related to this question of earning a CFII but not a CFI, I have not done
what follows and I am not sure the regs make sense in this area, but from a
strictly legal perspective I believe I can give an instrument proficiency
check in a multi-engine airplane even though I am not a multi-engine pilot.
My certificates are Commercial Pilot (ASEL + Instrument Airplane) and CFI
(Airplane Single Engine + Instrument Airplane).

Again I realize this may not make much sense from an instructional point of
view, but legally I do not see any reason I could not do this except (even
more oddly) that this would have to be done in actual IMC because I would
not be qualified to act as a safety pilot -- correct?

Perhaps somewhat more practically speaking, I see no reason why I could not
sign off an IPC done with my simulator (Level 3 FTD) in twin-engine mode
since I do not need to be PIC to "create" IMC in the simulator and my CFI
instrument privileges refer to instrument airplane and not specifically to
single- or multi-engine airplanes.

Indeed, extending this further, my understanding is that a non-pilot could
pass the written exam to become an Instrument Ground Instructor and then
without ever setting foot in an airplane he could do an IPC in the simulator
(again a Level 3 FTD) and this non-pilot would have the authority to sign
off the pilot of a cabin-class twin as safe to fly in IMC.

Again, I am not proposing any of these tasks as sane -- I am simply asking
whether my interpretation of the FARs is correct.

--------------------
Richard Kaplan, CFII

www.flyimc.com