Task-agnostic tabular foundation models such as TabPFN have achieved impressive performance on tabular learning tasks, yet the origins of their inductive biases remain poorly understood. In this work, we study TabPFN through the lens of signal reconstruction and provide the first frequency-based analysis of its in-context learning behavior. We show that TabPFN possesses a broader effective frequency capacity than standard ReLU-MLPs, even without hyperparameter tuning. Moreover, unlike MLPs whose spectra evolve primarily over training epochs, we find that TabPFN's spectral capacity adapts directly to the number of samples provided in-context, a phenomenon we term Spectral Adaptivity. We further demonstrate that positional encoding modulates TabPFN's frequency response, mirroring classical results in implicit neural representations. Finally, we show that these properties enable TabPFN to perform training-free and hyperparameter-free image denoising, illustrating its potential as a task-agnostic implicit model. Our analysis provides new insight into the structure and inductive biases of tabular foundation models and highlights their promise for broader signal reconstruction tasks.

Previous work has demonstrated that attention mechanisms are Turing complete. More recently, it has been shown that a looped 13-layer Transformer can function as a universal programmable computer. In contrast, the multi-layer perceptrons with $\mathsf{ReLU}$ activation ($\mathsf{ReLU}$-$\mathsf{MLP}$), one of the most fundamental components of neural networks, is known to be expressive; specifically, a two-layer neural network is a universal approximator given an exponentially large number of hidden neurons. However, it remains unclear whether a $\mathsf{ReLU}$-$\mathsf{MLP}$ can be made into a universal programmable computer using a practical number of weights. In this work, we provide an affirmative answer that a looped 23-layer $\mathsf{ReLU}$-$\mathsf{MLP}$ is capable to perform the basic necessary operations, effectively functioning as a programmable computer. This indicates that simple modules have stronger expressive power than previously expected and have not been fully explored. Our work provides insights into the mechanisms of neural networks and demonstrates that complex tasks, such as functioning as a programmable computer, do not necessarily require advanced architectures like Transformers.