My wife (Expat US citizen and now resident of India) draws government pension from the City and County of San Francisco. Article 19 - 2(a) and 2(b) of US - India tax treaty says her pension should be taxable ONLY by US. Is this Article excluded from the Saving clause? Haven't found a definitive answer to this question yet. From what I read, Saving clause in the treaty can completely negate the Articles listed in the treaty (unless it is specifically excluded, such as Article 20 on Social Security).
