Offline reinforcement learning seeks to utilize offline (observational) data to guide the learning of (causal) sequential decision making strategies. The hope is that offline reinforcement learning coupled with function approximation methods (to deal with the curse of dimensionality) can provide a means to help alleviate the excessive sample complexity burden in modern sequential decision making problems. However, the extent to which this broader approach can be effective is not well understood, where the literature largely consists of sufficient conditions. This work focuses on the basic question of what are necessary representational and distributional conditions that permit provable sample-efficient offline reinforcement learning. Perhaps surprisingly, our main result shows that even if: i) we have realizability in that the true value function of \emph{every} policy is linear in a given set of features and 2) our off-policy data has good coverage over all features (under a strong spectral condition), then any algorithm still (information-theoretically) requires a number of offline samples that is exponential in the problem horizon in order to non-trivially estimate the value of \emph{any} given policy. Our results highlight that sample-efficient offline policy evaluation is simply not possible unless significantly stronger conditions hold; such conditions include either having low distribution shift (where the offline data distribution is close to the distribution of the policy to be evaluated) or significantly stronger representational conditions (beyond realizability).