Hello – Thank you for contacting us!
Depending on where you are (i.e., in or outside of U.S.), the laws and tax codes about what constitutes a foundation vs. a true non-profit differ and are almost always complex. Consequently, your question is a great one - but it's outside of the scope of what I can answer. It would be best to consult an attorney who specializes in helping organizations gain non-profit status. Not all attorneys are familiar with the specifics of rules regarding non-profits. So, I’d make sure whomever you consult has done this kind of work before.
Best wishes in your efforts!