Technically, he would be. Kane only held the WWE/F title, and even then it was only for 24 hours before Austin won it back from him. He's never held the World/WCW title...
I refuse to consider the current Raw title the old WCW title. In my eyes, the only people who have held that "World Heaveyweight" title have been Triple H, Shawn Michaels, and Goldberg.