Easy. It has a TOSlink, Optical Digital Audio. No limitations in the hardware.
In fact, my AppleTV is CURRENTLY OUTPUTTING DTS 5.1 AUDIO, with no modifications at all.
See my post
here on the Forums for the details. However, if you have an AppleTV, iTunes, and time to download a 60 or 80MB DTS 5.1 reference file. Then you too can prove to yourself that there is nothing stopping 5.1 audio from playing on the AppleTV *unmodded*. It's all about the content baby!
And...the next release of Handbrake will properly encode the 6-channel audio so that our DVD rips have 5.1 and will play it on the AppleTV.
There is a great article on Digg that you should check out, I didn't post it, but I'd like people to Digg it up so we can once and for all settle this discussion and get more of these into people's hands.
Here's the article on Digg:
Ten Myths of the Apple TV 5.1 Audio
-Rob