For the OP, if you are just looking to set up a file server, Samba is definitely a good option. One thing that wasn't clear to me is whether you plan to use one of the 10 machines as a server, or if you are going to buy a dedicated server. Cause the specs you posted won't really cut it for a server.
If he adds a bit more ram (for disk cache) and throws in a 500 gig drive or so then it should be fine. Although obviously if you check out Dell's website you can get a small end server with much better specs for dirt cheap.
But I'm intrigued by your first post. Are they planning on putting group policy like functionality in Samba 4? Or what do you mean by a more complete AD replacement?
Well currently you can setup NT-style workgroups, more or less. Supports Netlogin protocol (rather then Kerberos found in AD). Set it up so that you have a domain controller to log into and have a central place for managing users and I beleive things like roaming desktops. There are a few advanced features you can have, like shadow folders (taking advantage of LVM's shadow features) which is compatable with the GUI applications and such you can get (I don't know how stable or usefull it is though. LVM snapshot stuff is fairly new). Supports ACLs (through translating Linux 'posix' extended ACLs to match it. There are a few caveots, but I don't know what they are)
If you want to get very advanced you can go with Samba, Kerberos, OpenLDAP and Winbind for larger things.
(keep in mind that I never realy used this stuff before besides playing around and reading about it. I realy need to take a deeper look at it.)
So that will give you more or less a idea were Samba 3 is at now.
Now with Samba 4 it is currently a sort of technological play ground. They have several plans for it..
One big thing for Linux users is that they want to turn CIFS into a 'native' network protocol for Linux. Detect weither or not both client and server are Linux and then bypass windows compatability stuff for better performance and higher file system level compatability. Make it suitable for shared home directories and network booting.
Now on the Active Directory side I know less.
but this article gives a pretty good overview:
http://www.zdnetasia.com/toolkits/0,39047352,39353602-39094244p,00.htm
Most of it will stem from having proper kerberos-based login support for windows clients with Microsoft's extension to that.
Along with the normal functionality upgrades you expect between major revisions of software. It's a pretty big change.