So psychology comes into play and that is basically impossible to "solve" unless we have real AI (not anytime soon and the implication would be way broader than "beating Hold'em").
Fixed-limit Hold'em is easier to play because the decision tree is trivial. It's still an imperfect information game but the best bots can already beat some of the best professional players.
But No-Limit Hold'em is another thing entirely: the decision tree is so huge that it's impossible to bruteforce. Impossible as in: unless a major scientific discovery we'll never ever be able to bruteforce it (there's not enough entropy in the know universe to do so).
So we're stuck and waiting for amazing discoveries in the AI field (and psychology field).