I'm wondering which invalid assumptions are most likely to explain the wild discrepancies between a model's R-squared as a measure of predictive performance, and the actual out-of-sample predictive accuracy of a model.
Although it is known that in the standard OLS case the R-squared criterion, $R^2 = 1 - \frac{\text{SS}_\text{reg}}{\text{SS}_\text{tot}}$ - the percentage of variance explained by a model as measured by the remaining sum of squares in the model relative to the total sum of squares in the data - tends to over-estimate the predictive power of linear models since it does not address the process of fitting the model in terms of the degrees of freedom used to model the data.
The adjusted R-squared criterion, $R^2 = 1 - \frac{\text{SS}_\text{reg}}{\text{SS}_\text{tot}} \frac{n - 1}{n - p - 1}$ scales the standard R-squared downwards to address this issue (similar to the scaling of the estimate for the population variance), with $p$ the number of coefficients estimated and thus the last term being less than 1.
However, when testing the accurateness of the $R^2$ in real-world applications as an estimate of predictive power, it often seems to be the case that the adjusted R-squared (and thus also the normal R-squared) grossly over-estimates the predictive performance of a model in terms of out-of-sample prediction (e.g. using a cross-validation or test/train split on the data).
Intuitively, this will have to do with the invalidity of the assumptions of linearity and additivity which are usually present in linear regressions but I'm wondering what the largest sources of discrepancy would be?