This might be a stupid question..

Yes, the sole manipulator can always log the time as PIC if he has the appropriate type rating. Part 121/135/91, etc, is irrelevant, because Part 61 applies to everyone.

However, that sort of PIC time is probably useless to you in your career once you reach the Part 121 stage. Others advise you not to log it as such and some airlines specifically ask you to exclude such time from your PIC totals.

Bingo.

There are, however, some Part 91 and 135 operators that will allow the use of sole manipulator PIC time in their internal operations for calculating PIC time. (Note I say "some", not "all" nor even "many".) For this reason I think that it is acceptable to keep a separate logbook column for this type of PIC time. I call it "Part 61 PIC" in my logbook. The PIC column is reserved for true designated-on-the-flight-release-as-PIC time, and the Part 61 PIC is used when I am designated by the company as SIC, yet am the sole manipulator of the controls (and I'm appropriately type rated in the plane). We actually swap seats and the pilot flying in the left seat is treated, for all practical purposes (although not necessarily regulatory purposes) as the PIC of the flight and makes all decisions as such (utilizing proper CRM techniques of course). It is not unheard of in some corporate and charter operations to have both pilots be fully type rated and captain qualified, and to swap seats no matter whose name is on the flight release.

This kind of logging would apparently be worthless in the 121 world, and I would be very upfront about using Part 61 PIC when talking/interviewing with a corporate or charter operator, but there are some cases where it can be useful. So I log it but keep it clearly separate. It is very easy to add the "Part 61 PIC" time into either the SIC or the PIC column depending upon which way the company wants to see it.

YMMV.
 
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