We offer a theoretical characterization of off-policy evaluation (OPE) in reinforcement learning using function approximation for marginal importance weights and $q$-functions when these are estimated using recent minimax methods. Under various combinations of realizability and completeness assumptions, we show that the minimax approach enables us to achieve a fast rate of convergence for weights and quality functions, characterized by the critical inequality \citep{bartlett2005}. Based on this result, we analyze convergence rates for OPE. In particular, we introduce novel alternative completeness conditions under which OPE is feasible and we present the first finite-sample result with first-order efficiency in non-tabular environments, i.e., having the minimal coefficient in the leading term.