Recent work analyzing in-context learning (ICL) has identified a broad set of strategies that describe model behavior in different experimental conditions. We aim to unify these findings by asking why a model learns these disparate strategies in the first place. Specifically, we start with the observation that when trained to learn a mixture of tasks, as is popular in the literature, the strategies learned by a model for performing ICL can be captured by a family of Bayesian predictors: a memorizing predictor, which assumes a discrete prior on the set of seen tasks, and a generalizing predictor, where the prior matches the underlying task distribution. Adopting the normative lens of rational analysis, where a learner’s behavior is explained as an optimal adaptation to data given computational constraints, we develop a hierarchical Bayesian framework that almost perfectly predicts Transformer next- token predictions throughout training—without assuming access to its weights. Under this framework, pretraining is viewed as a process of updating the posterior probability of different strategies, and inference-time behavior as a posterior- weighted average over these strategies’ predictions. Our framework draws on common assumptions about neural network learning dynamics, which make explicit a tradeoff between loss and complexity among candidate strategies: beyond how well it explains the data, a model’s preference towards implementing a strategy is dictated by its complexity. This helps explain well-known ICL phenomena, while offering novel predictions: e.g., we show a superlinear trend in the timescale for transitioning from generalization to memorization as task diversity increases. Overall, our work advances an explanatory and predictive account of ICL grounded in tradeoffs between strategy loss and complexity.