I have this image in my head that R&D is some boffins in the back room inventing a something new, and then expanding on that idea is execution.

But "and development" covers everything we do in software development. Whether you fix a bug or write some documentation you are developing the product in some small way.

I imagine some business will need to restructure so the US arm is paying a service contract to use the software, and the foreign arm will own and develop the software.