The problem is that I wouldn't want to lose the saved clips. The situation hasn't called for pop yet. In my file format, clear is a legal state. A clear clip region can even be pushed onto the stack.
Like I said, I have a work-around implemented where I treat a clear instruction as a replace-with-device-rect set of instructions.
It works, but I suspect that the performance during those periods -- where the clip region is supposed to be clear -- are not as fast as actually having it be clear. There is probably an optimization in there that says "don't bother with clip testing, if the current clip is clear".