Businesses, as opposed to individuals, can discharge the debts described in 11 U.S.C. § 523(a) with cramdown plans under Subchapter V of the Bankruptcy Code. There are two routes for plan confirmation available to debtors in cases under Subchapter V.
If a consensual plan is confirmed under 11 U.S.C. § 1191(a), discharge of debts is governed by 11 U.S.C. § 1141. Read together, sections 1141(d)(1) and (d)(3) provide that corporate debtors receive a discharge of otherwise non-dischargeable debts. But Section 1141(d)(2) provides that individual debtors do not receive a discharge of those same non-dischargeable debts.
If a cramdown plan is confirmed under 11 U.S.C. § 1191(b), discharge is governed by 11 U.S.C. § 1192. In a case of first impression, Maryland bankruptcy court Judge Maria E. Chavez-Ruark held that a corporation can discharge debts listed in Section 523 and that the exception to discharge under Sections 1192 and 523 is limited to individuals.
 Gaske v. Satellite Restaurants Inc. Crabcake Factory USA (In re Satellite Restaurants Inc. Crabcake Factory USA), 21-00012 (Bankr. D. Md. March 19, 2021).