The way I read all that stuff in the FSIMS, all they'll do without a test is give you a Private. Looks like they used to let you walk out with a COMM but won't anymore.
Applicability. This section applies to the issuance of U.S. pilot certificates and ratings to persons who apply on the basis of their foreign pilot licenses under the following rules within part
61:
1) Under § 61.29, for persons who request replacement of a certificate issued on the basis of a foreign pilot license under § 61.75. You're not getting a replacement.
2) Under § 61.39(c)(1), for persons who hold a foreign pilot license (issued by an ICAO member state that authorizes at least the pilot privileges of the U.S. pilot certificate sought) and apply for an equivalent U.S. pilot certificate. Says you don't need a sign off to take the practical test.
3) Under § 61.65, for persons who apply for an instrument rating on a § 61.75 U.S. pilot certificate with the notation “U.S. TEST PASSED.” U.S. test passed is a hint.
4) Under § 61.73(b)(3)(ii), for a rated military pilot of a foreign armed force whose country is a Member State of ICAO, and that pilot is assigned to pilot duties (other than flight training as a student) of an operational U.S. military unit and who holds at the time of application a current civil pilot license issued by the foreign country, which authorizes at least the privileges of the U.S. pilot certificate sought. Don't think we're talking military.
5) Under § 61.75, for persons who apply for a § 61.75 private pilot certificate on the basis of holding a foreign pilot license (at least equivalent to or higher than the U.S. private pilot certification level) issued by an ICAO member state. Apply for a PVT.
6) Under § 61.75(c), for persons who apply for the addition of an aircraft rating to a § 61.75 U.S. pilot certificate with the notation “U.S. TEST PASSED.” 61.75 gets you a PVT without a checkride.
7) Under § 61.75(d), for persons who apply for an instrument rating to a § 61.75 U.S. pilot certificate by accomplishing the Instrument Foreign Pilot (IFP) knowledge test. Again, at the PVT level and a written test.
8) Under § 61.123(h), for persons who apply for an unrestricted U.S. commercial pilot certificate on the basis of holding a § 61.75 U.S. pilot certificate. Gets you out of the requirement to hold a FAA PVT before you get the COMM.
9) Under § 61.153(d)(3), for persons who hold either a foreign Airline Transport Pilot License (ATPL) with the appropriate aircraft rating or a foreign commercial pilot license (CPL) and instrument rating with the appropriate aircraft rating, without limitations, who apply for a U.S. ATP certificate. Holding a foreign ATP gets you out of the requirement to have a FAA COMM before you get the FAA ATP.