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There are three types of claims: priority, secured, and unsecured. Priority claims are those granted special status by the bankruptcy law, such as most taxes and the costs of bankruptcy proceeding. (3) Secured claims are those for which the creditor has the right take back certain property (i.e., the collateral) if the debtor does not pay the underlying debt. In contrast to secured claims, unsecured claims are generally those for which the creditor has no special rights to collect against particular property owned by the debtor.
The first three peer reviews, conducted between 2017 and 2020 ( Compilation of Phase 1 Peer Review Reports , Compilation of Phase 2 Peer Review Reports and Compilation of Phase 3 Peer Review Reports ), reflected the phased implementation of CbC reporting and focused on different aspects of the key areas under review, being the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of CbC reports. Subsequent peer reviews, conducted since 2020, consider all aspects of a jurisdictions implementation of CbC reporting annually ( Compilation of 2021 Peer Review Reports, Compilation of 2022 Peer Review Reports ).
In this context, section 523(a)(2) acts as an exception to discharge and provides that debts for fraud are nondischargeable. Id. at 1327. To be nondischargeable, a debt must meet four conditions: (1) it must be for money, property or services; (2) it must represent a statement of fact by the debtor that it is true; (3) it must have been made with the intent to deceive; and (4) it must have been material. Id. (citing Household Finance Corp. v. Danns, 558 F.2d 114, 116-17 (2d Cir. 1977)).
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