Some Green Card holders and #Americansabroad living in Belgium are like Alice in her "Adventures In Wonderland". You see they have @taxresidency in the USA, but when they move to Belgium they "changed" to NOT being "residents of the United States" and are denied certain benefits. 
Note that the standard "saving clause" confirms the right of the countries to tax their "residents" (as defined in Article 4) and "citizens" (without regard to anything). As always, there are certain exceptions to the "saving clause". Here is paragraph 4 of Article 1 ...
Next we move to Article 4 (the usual residency article) and note that US citizens and Green Card holders ARE defined as US tax residents under US law. Therefore, they are presumptively residents of the USA under the treaty ...
Now we note paragraph 2 which requires specific conditions in order for US citizens or Green Card holders to be "residents of the United States" for the purposes of the treaty ...
The full text of the US Belgium Tax Treaty is here ... irs.gov/pub/irs-trty/b…
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