I logged my 1032 hours of actual instrument when I was in the clouds. I did not log any of my 2028 hours of night as actual instrument (unless I was in a cloud at night), even if it was moonless, on top, no horizon, etc. I guess it is true that you have to fly on instruments in that case, but since I was using an autopilot anyway, I don't feel like I should. I've always used clouds/IMC as my actual instrument time. I'm IFR all of the time.
Side note: It was VMC today flying over Greenland. It was a beautiful site. Normally, I don't get to see it.