In the wee hours of Jan. 1, 2013, the U.S. Senate passed H.R. 8, the American Taxpayer Relief Act by a margin of 89 to eight. The American Taxpayer Relief Act (“ATRA”) extends the majority of tax cuts that were scheduled to expire at the end of 2012, in addition to retroactively reinstating several rules that had expired in 2011.  As expected, the legislation also introduced a number of changes including a new top tax bracket of 39.6% and an increase in the top long-term capital gains and…