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This paper studies off-policy evaluation (OPE) in reinforcement learning with a focus on behavior policy estimation for importance sampling. Prior work has shown empirically that estimating a history-dependent behavior policy can lead to lower mean squared error (MSE) even when the true behavior policy is Markovian. However, the question of *why* the use of history should lower MSE remains open. In this paper, we theoretically demystify this paradox by deriving a bias-variance decomposition of the MSE of ordinary importance sampling (IS) estimators, demonstrating that history-dependent behavior policy estimation decreases their asymptotic variances while increasing their finite-sample biases. Additionally, as the estimated behavior policy conditions on a longer history, we show a consistent decrease in variance. We extend these findings to a range of other OPE estimators, including the sequential IS estimator, the doubly robust estimator and the marginalized IS estimator, with the behavior policy estimated either parametrically or non-parametrically.